December 2025 – On 15 December 2025, the Romanian Parliament adopted Law no. 239, which will enter into force on 18 December 2025. The law introduces significant amendments to the Fiscal Procedure Code, the Fiscal Code, and other related regulations. The main changes are presented below:
Legislative updates regarding legal entities
- As of 1 January 2026, taxpayers which had in the previous year a turnover below EUR 50 mil. (note: those not subject to IMCA), incurring expenses related to intellectual property rights, management, advisory from non-resident affiliated parties, where such expenses exceeded 1% of the total expenses according to 2024 accounts, may deduct these expenses, in the current tax year (2025 and 2026), up to 1% of their total costs. Starting with 2027, the 1% threshold will be determined based on expenses reported in the tax return for the current tax year. These provisions do not apply to taxpayers holding an advance pricing agreement or to those requesting one valid from 2027.
- Starting 1 January 2026, failure to submit annual financial statements within 5 months from the legal deadline will cause the taxpayer to be designated „inactive”.
- For taxpayers declared inactive before this law enters into force, the tax authorities must request dissolution if re-activation does not occur within 12 months. For temporarily inactive companies registered as such with the Trade Registry, the request for dissolution will be made after the period of inactivity expires if business has not resumed.
- The conditions for obtaining tax payment plans become harsher. Inter alia, corporate taxpayers must provide an authentic surety contract with their beneficial owner (within 30 days from the law’s entry into force for certain pending requests for granting/modifying/maintaining already approved plans).
- Payment plan applications under the simplified procedure, submitted after these provisions enter into force, will be subject to thresholds related to the value of liabilities which can be included in said plans (for individuals between RON 500 and RON 100,000 lei; legal entities between RON 5,000 and RON 400,000).
Legislative updates regarding individuals
- Starting 1 January 2026, the tax rate on income from transfers of securities and derivative financial instruments through brokers will increase:
- From 1% to 3% (holding > 365 days);
- From 3% to 6% (holding < 365 days).
- Starting 1 January 2026, the tax on gains from transfers of securities (including shares), other financial instruments, virtual currency transfers and investment gold, will increase from 10% to 16%. This applies to transactions not performed through brokers.
- Starting 1 January 2026, the maximum threshold for health insurance contributions (CASS) owed by individuals earning income from independent activities will increase from 60 to 72 gross minimum wages.
Other legislative updates
- Starting 1 November 2025, a logistics fee of RON 25 will be introduced for managing flows of non-EU goods, for each postal parcel containing goods with a commercial value below EUR 150, entering in Romania from outside the EU.
- The fee is owed by the suppliers of the respective goods, the consignors, or the electronic platform facilitating the sale, and postal service providers are responsible for collecting, declaring, and remitting the fee.
- Romania will implement the RO e-Proprietate system, a national integrated system for managing fiscal data and information on real estate in Romania.
- Starting 1 January 2026, new rules for computing the tax on buildings, land, and vehicles will apply, including substantially increased tax rates and taxable values. Additionally, the granting of certain existing tax exemptions will become optional for local authorities.
- As of 1 January 2026, the rate for the special tax on high-value real estate and movable assets will increase from 0.3% to 0.9% for residential buildings valued over RON 2,500,000 and for vehicles valued over RON 375,000.