In the context of the commitments made through Romania’s National Recovery and Resilience Plan (PNRR), Romania is preparing to reintroduce a car tax for polluting vehicles.

In the context of the energy transition and the encouragement of using renewable energy sources, the National Agency for Fiscal Administration (ANAF) has issued clarifications regarding the application of the reduced VAT rate for storage batteries used in photovoltaic systems.

Starting in 2025, taxpayers who obtain income from the use of assets must pay attention to the new tax regulations imposed by the National Agency for Fiscal Administration (ANAF).

The Ministry of Finance has published a draft emergency ordinance that introduces a series of significant amendments to the Fiscal Code, primarily aiming to align Romanian legislation with EU directives on value-added tax (VAT).

The FASTER Directive (Faster and Safer Relief of Excess Withholding Taxes) is a European Union (EU) initiative aimed at simplifying and harmonizing procedures for the relief of excess withholding tax.

Starting January 1, 2025, small and medium-sized enterprises (SMEs) in the European Union will have to comply with new VAT rules designed to simplify compliance and enhance cross-border trade opportunities, while also presenting various challenges.

At the end of 2024, the Romanian Government approved the reintroduction of the construction tax, previously known as the “pillar tax.” Although the rate has been reduced from 1.5% to 1%, the new version introduces significant changes that may pose substantial challenges for taxpayers. The tax will be collected starting from the second half of 2025.

Transfer pricing is a highly discussed topic in Central and Eastern European countries. These prices are particularly important for companies that are part of multinational groups or affiliated with other companies, as they influence tax compliance and intra-group financial flows. To avoid tax adjustments imposed by tax authorities, companies can opt for advance pricing agreements, thus offering greater financial predictability.

Fiscal inspection represents a process by which authorities check whether taxpayers comply with their tax obligations. In order to avoid legal problems and to efficiently manage a fiscal inspection, companies must be well prepared.

The Romanian government has recently introduced the “Trenuleț” Ordinance, a legislative measure that brings significant changes to the tax regime applicable to certain strategic sectors of the economy.

The year 2025 brings significant tax changes that will influence how companies conduct their activities and manage their tax obligations. This newsletter is designed to help you understand the new regulations and prepare accordingly.

BEFIT (Business in Europe: Framework for Income Taxation) is a proposal by the European Commission, launched on September 12, 2023, aimed at creating a unified corporate income tax system within the European Union.

The Ministry of Finance proposes a draft Emergency Ordinance (EO) to support strategic investments in the manufacturing industry.

CbCr (Country-by-Country Reporting) and Public CbCr are important tools for enhancing the fiscal transparency of multinational companies. They show how revenues, profits, and other financial information of corporate groups are distributed across different countries.

On Thursday, December 5, 2024, Emergency Ordinance no. 138/04.12.2024 was published in the Official Gazette no. 1222, introducing clarifications and amendments to RO e-Invoice, RO e-VAT, and RO e-Transport, as well as changes to the Fiscal Code and the Accounting Law.

e-Factura is an electronic platform developed by ANAF (Romanian tax authority) that centralizes all issued invoices into a database. Its primary aim is to enable authorities to monitor economic transactions in real-time, thereby reducing tax evasion.

In brief, transfer pricing refers to the prices at which companies within the same group sell products, provide services, or offer loans to each other. These prices must resemble those used between independent companies—essentially, they should reflect a “fair market price.”

The European Union has introduced the Carbon Border Adjustment Mechanism (CBAM) as part of its strategy to reduce carbon emissions, targeting imports of carbon-intensive goods.

The ordinance introduces a significant novelty: the extension of tax benefits for research and development (R&D) activities to companies that are now required to pay the minimum turnover tax (MTT).

The new document, called the special notice to accompany the goods, is mandatory for all traders operating in the cash & carry regime

The net margin method (TNMM) is one of the methods approved by the OECD guidelines

The rules regarding the tax amnesty established by GEO 107/2024 have already been modified by GEO no. 112/2024, applicable starting from September 25, 2024

Emergency Ordinance no. 107/2024 introduces the following fiscal measures for all categories of taxpayers

Transfer pricing is central to the management of intra-group transactions for multinational companies

On January 8, 2024, Law 431/2023 entered into force, transposing the provisions of Directive 2523/2022 into the national legislation of Romania

According to the strategy of the National Fiscal Administration Agency (ANAF), collection efficiency will improve by supporting fiscal compliance, with particular emphasis, and by combating fiscal evasion

The resale price method is mainly used by companies whose operational profile includes marketing and distribution activities

As mentioned in the OECD Transfer Pricing Guidelines, the functional analysis according to the essential determination and presentation of relevant information about the company

The application of the e-Transport system would be significantly expanded starting in July, as it appears from an draft order from ANAF

Law 431/2023 was published on December 29, 2023 on ensuring a global minimum level of taxation of multinational enterprise groups and large national groups

The net margin method is one of the most widely used transfer pricing assessment methods

The transfer pricing comparison method is a commonly used method for assessing transfer prices for transactions between related entities

Advance pricing agreements are tools used in transfer pricing to avoid disputes between taxpayers and tax authorities regarding the correct assessment of transfer pricing

In recent years, in the framework of fiscal controls carried out at the level of companies in Romania, increased attention has been paid to the verification of the transfer pricing file

Preparation of the transfer pricing file, the appeals, the preparation of the comparability studies must be prepared by a specialized tax consultant

Currently, an employee contributes monthly to social insurance (CAS) with a percentage of 25% of his gross salary

On the website of the Ministry of Finance, on September 19, the Draft “LAW on some fiscal and budgetary measures to ensure the financial sustainability of Romania in the long term” was published

They say that people don’t change, they just become more and more what they really are, and Marian is the example that confirms the thesis

The Cabot Transfer Pricing seminar at the Tax EU Forum was a real success

We have chosen to join the Narada cause in their endeavour to make Romanian Schools safe by investing in infrastructure solutions, furniture, technology and more

Where to find us this Fall

On Monday, September 20, I took part as a BusinessMark speaker at one of the annual events already on the public agenda – CFO Conference

The time has come for our image to accurately reflect what we already embody in our day-to-day practice – speed, efficiency, precision.