The tax authority released a draft form for notifying and designating entities to handle domestic top-up tax under Pillar Two rules.
Romania’s National Agency for Fiscal Administration (ANAF) released a draft order on 20 June 2025 outlining the template and content for the “Notification concerning the obligation to declare and pay the domestic top-up tax” under Pillar Two rules.
The measure is based on Law No. 431/2023, which came into force on 8 January 2024, implementing the OECD’s global minimum tax framework. The draft form remains subject to approval and may be amended.
The draft notification requires several key pieces of information. These include details of the submitting entity, such as its name, tax identification number, address, and status for Pillar Two purposes (e.g., ultimate parent entity, constituent entity, or designated entity). It also requires identification of the multinational enterprise (MNE) group or large domestic group, including the name used in the consolidated financial statements.
Additionally, the form must include information on all Romanian constituent entities, such as their names, addresses, tax ID numbers, and designation status. It must also specify the local designated entity responsible for declaring and paying the domestic minimum top-up tax (DMT). Finally, the notification must provide fiscal year details—covering start and end dates and whether it is the first reporting year—as well as contact details of the submitting entity.
