The Romanian government has adopted GEO No. 22/2025 introducing significant amendments to Romanian VAT legislation and directly affecting small enterprises and VAT registration procedures. The new rules transpose EU provisions into domestic law and aim to ensure a more uniform application of the small business exemption regime across the EU effective 1 September 2025. 1. Updates to the special VAT exemption regime for small enterprises Annual turnover limit for VAT exemption eligibility has increased from RON 300,000 to RON 395,000 (approx. EUR 77,000). Transitory provisions are introduced for companies that exceeded the previous eligibility threshold in August 2025. 2. Cross-border VAT simplification
A new funding opportunity in Romania—the DR-23 Investments for the Processing of Agricultural Products Aid Scheme—has been launched following its publication in the Official Gazette, offering significant financial support to businesses operating in the agri-food sector. With a total budget of approximately EUR 165 million, this scheme is designed to support a wide range of companies operating in the food industry in Romania, including but not limited to bakeries, milling units, biscuit and pasta producers, chocolate and cocoa manufacturers, ice cream producers, and even beer makers. Who can apply? The funding scheme is open to a variety of Romanian enterprises in the agri-food sector, including:
The Romanian tax authorities have recently enacted legislative changes concerning advance pricing agreements (APAs), with the aim of enhancing the regulatory framework and supporting tax compliance. Key amendments include: The introduction of the possibility to request the issuance of an APA for historical transactions, with retroactive application of up to five years, subject to conditions that will be detailed in secondary legislation. The option for the tax authorities to suspend tax audits for periods covered by submitted APA requests, in order to prioritise their resolution. A revision of the mutual agreement procedure for the avoidance of double taxation, aimed at facilitating the resolution
On 25 July 2025, the Romanian Parliament adopted Law 141/2025 regulating a series of important fiscal changes that will enter into force starting August 2025, as summarised below. ⇒ Increase of the dividend tax from 10% to 16% for all taxpayers obtaining income from dividends, i.e., companies, individuals, and non-residents. The increased tax applies to dividends distributed starting 1 January 2026. Certain transitory rules will apply to dividends distributed based on interim financial statements prepared during 2025 (or a modified fiscal year starting in 2025). ⇒ Increase of the supplementary turnover tax for credit institutions (including banks) as follows: from 2% to 4% for the period 1 July
Kinstellar is pleased to announce that it has advised Special Flanges, a leading Italian manufacturer of high-performance forged components, on the acquisition of 100% of the shares in Vilmar, a Romanian industrial company with over 50 years of experience in the production of engineered equipment for critical applications. The transaction marks Special Flanges’ first direct investment in Romania and represents a key milestone in the group’s strategic expansion across Central and Eastern Europe. The acquisition was carried out by the Wise Equity V fund managed by Wise Equity SGR – through its subsidiary Special Flanges – and involved the transfer of Vilmar from the French group Genoyer. The integration will create
Ukrainian taxpayers operating within multinational enterprise groups (MNEs) with consolidated annual revenues exceeding EUR 750 million may, for the first time in 2025, be required to independently file Country-by-Country (CbC) reports. This applies in particular to companies that are part of MNEs with a U.S.-based ultimate parent entity. Please read the complete overview below in English or in Ukrainian. Download in English: Download in Ukrainian:
At Kinstellar, we understand that tax audits and disputes can pose significant challenges to businesses. To better serve our clients in this critical area, we have brought together our tax advisory and litigation teams into a dedicated Tax Disputes & Audit Task Force. This newly established task force combines the full strength of our tax and legal expertise to support companies facing the risk—or the reality—of a tax inspection or fiscal litigation. Our professionals work hand-in-hand to help you anticipate risks, prepare your teams, manage the audit process, and defend your case with confidence in all procedural phases. Whether you're seeking to avoid future exposure, handle an ongoing audit, or resolve
On 2 May 2025, the Austrian Ministry of Finance published a draft bill of the Budget Accompanying Act proposing significant amendments to the Austrian Real Estate Transfer Tax Act with potential far-reaching implications for M&A transactions. The proposed changes to the Real Estate Transfer Tax Act would tighten the tax treatment of so-called “share deals”—transactions where shares in corporations or partnerships owning real estate are transferred instead of the real estate itself. These changes, aligned with the Austrian government’s 2025–2029 program, aim to close any existing loopholes that have enabled the avoidance of real estate transfer tax in real estate transactions. Reduction of the ownership
Historically, customs duties are considered to be the origin of taxation. Today, looking specifically at the current U.S. administration, customs duties—better known as tariffs—are primarily used as tools of trade policy. Rising customs duties are creating uncertainties for multinational companies and supply chains. With the ongoing increases in customs duties, the question arises: How can multinational companies adequately address new tariff regulations from the tax law perspective? Customs valuation review Rising customs duties can significantly impact the cost structure of imported/exported goods and, thus, disrupt carefully planned transfer pricing arrangements and related intercompany agreements between
As described in our previous newsletter in September 2024, profit taxpayers and microenterprise income tax taxpayers in Romania benefit from a 3% discount of their annual profit/income tax liability related to fiscal year 2024/the modified fiscal year starting in 2024. The procedure for applying the aforementioned discount was approved by Order 540/2025 published on 14 April 2025. To benefit from this discount, taxpayers need to fulfil the following conditions: they must have all mandatory tax returns submitted in due time; the annual profit/income tax related to fiscal year 2024/the modified fiscal year starting in 2024, as the case may be, is paid in full within the applicable legal deadlines;
Kinstellar is delighted to announce that Maja Mayrhuber, a reputable tax lawyer, has joined our newly launched Vienna office as a Partner. Maja’s arrival marks an important step in building our tax capabilities in Austria and driving the growth of this service line across the wider C/SEE region. Maja Mayrhuber specialises in national and international tax law, with a focus on corporate taxation, tax planning, and tax advice related to international restructurings, M&A, corporate finance, and real estate transactions. Maja regularly advises both international companies and private clients on a broad spectrum of tax issues, including VAT, tax audits, transfer pricing, and fiscal criminal law. She also represents clients
On 4 April 2025, Romania government Emergency Ordinance no. 21/2025 ("the GEO") was published and entered into force, introducing several important amendments and clarifications regarding the recently enacted construction tax. We summarise the main provisions below. Reduction of the tax rate: The construction tax rate has been decreased from 1% to 0.5%. Tax base clarification: It is now explicitly clarified that the 0.5% tax applies to the net book value of constructions. New separate tax (0.25%): A separate tax of 0.25% has been introduced for buildings belonging to the public or private domains of state or administrative-territorial units that are utilised based on contracts, agreements, or legal