Romania’s new 2026 tax measures introduce a 1% cap on certain payments to foreign affiliates, adjust corporate and micro-enterprise taxation, tighten rules for excise goods and digital reporting, and revise vehicle and high-value asset taxes, with most changes taking effect from 1 January 2026.
Romania has published Law No. 239/2025 and Emergency Ordinance No. 89/2025, which introduce a 1% cap on deductions for payments to non-resident related parties for intellectual property and management or consulting services. The limit applies to companies with a turnover of less than EUR 50 million.
For 2026, the cap is based on 2024 expenses if they exceed 1% of total expenses; from 2027 onward, it applies to the same-year expenses that exceed 1% of total costs. Exemptions to the 1% deduction cap include transactions covered by a Romanian advance pricing agreement (APA), intellectual property registered in Romania, expenses capitalised as assets under accounting rules, or taxpayers that are Romanian credit institutions.
Other Key provisions include adjustments to the tax code, such as setting a 0.5% tax rate on specific turnover thresholds in 2026 and refining the tax regime for micro-enterprises. Furthermore, it introduces rigorous monitoring for excisable goods, mandates new registration requirements for alcohol and tobacco distributors, and updates the RO e-Factura and RO e-TVA digital systems.
Other notable changes are as follows:
Corporate taxation
The new legislation introduces significant changes to how companies are taxed and structured:
- Minimum tax on turnover: For the 2026 fiscal year, the minimum tax rate in the formula is 0.5%. This applies to large taxpayers (over EUR 50 million in turnover), with specific rules governing the maintenance of assets in their patrimony for at least 5 years if they were used to reduce the tax base.
- Micro-enterprise tax: Starting 1 January 2026, the tax rate on micro-enterprise income is set at 1%.
- LLC share capital: The minimum share capital for Limited Liability Companies (SRL) is now tied to net turnover. For companies with a turnover exceeding RON 400,000, the minimum capital must be RON 5,000. Newly established companies must have a minimum capital of RON 500. Existing companies must comply with these new limits within 2 years of the law’s entry into force.
- Affiliated transactions: Deductibility for intellectual property, management, and consultancy fees paid to foreign affiliates is limited to 1% of total expenses if the taxpayer’s turnover is below EUR 50 million.
Fiscal discipline and digitalisation
- RO e-Factura: The deadline for transmitting electronic invoices is five working days from the date of issue. Failure to comply or use the system correctly for B2C (business-to-consumer) transactions or by individuals using their personal numeric code for business is now strictly regulated.
- RO e-Proprietate: A new national, integrated system has been established to manage real estate data for fiscal purposes, requiring all public authorities to provide property data to the Ministry of Finance at no cost.
- Inactive companies: Legal entities are declared inactive if they do not have a payment account in Romania or fail to file annual financial statements within five months of the legal deadline. If they remain inactive for one year, the fiscal organ must initiate dissolution proceedings.
Excise goods and logistics tax
New controls are placed on high-risk products and non-EU imports:
- Logistics tax on non-EU parcels: Effective 1 January 2026, a RON 25 tax is instituted for every parcel containing goods with a commercial value under EUR 150 entering Romania from outside the European Union.
- High-risk excise operators: Operators in the alcohol, tobacco, and energy sectors deemed “high fiscal risk” must provide a guarantee of 120% of the excise value for intended shipments.
- Re-authorisation: Between 1 March and 31 May 2026, all authorised excise operators (warehouse keepers, importers, etc.) must apply for re-authorisation under the new stricter criteria.
Other tax changes
- Vehicle taxes: Vehicle local taxes are now determined by engine size and emissions standards (from Non-Euro to Euro 6). For example, motorcycles up to 1,600 cm³ are taxed between RON 16.2 and RON 19.5 per 200 cm³, depending on their emissions. Electric vehicles are subject to a flat annual tax of RON 40.
- Tax on high-value assets: The special tax on high-value assets—residential properties over RON 2.5 million and vehicles over RON 375,000—has been raised from 0.3% to 0.9%.
These changes take effect from 1 January 2026.
