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 ordinance brings a significant novelty: the extension of tax facilities for research and development (RD) also to companies that have become obliged to pay the minimum turnover tax (MTO)

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

Companies operating commercial vending machines risk, starting in October, significant fines and additional sanctions if they do not equip these machines with electronic tax cash registers

Multinational companies with a presence in Romania, have the obligation to publish a detailed report on the profit tax paid in each member state of the EU

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

Cabot Transfer Pricing is a partner of the CFO Conference 2024 event, and Alina Andrei, Partner of Cabot Transfer Pricing, is the Speaker of this event

The Ministry of Finance published a press release explaining precisely that the deadline for submitting invoices in the RO e-Invoice system is five calendar days from the date of the invoice

The digital transition has been, in recent decades, a catalytic force for economic, social and cultural changes at global level

ANAF recently published the order approving the model and content of the “RO e-TVA Compliance Notification” form

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

A simple post on a social network has no real value, from the perspective of the taxpayers’ relationship with the MF and the ANAF

ANAF has published the official form for the pre-completed e-TVA return, which will be implemented starting August 1, 2024

The e-Transport system has, since July, a new application procedure, the old one being removed and completely replaced

The National Fiscal Administration Agency has published on its website the new nominal lists of large and medium taxpayers, valid from July 1

A few days after the regulation of the new VAT system, the Ministry of Finance nuanced and completed the legal provisions so that the system is easier for companies to manage

What impact do all the overnight announced tax changes have on business?

The last major deadline in the calendar for the implementation of the standard tax control file (SAF-T), which targets small taxpayers, is fast approaching

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

As July 1, 2024 approaches, companies in Romania must prepare for a series of significant changes related to the e-Factura, e-Transport and e-TVA system

Companies paying corporate income tax must report and pay their taxes for the tax year 2023 by June 25 at the latest

Starting June 1, companies must be extremely careful about the new e-invoicing obligations, as the penalty-free grace period ended on May 31

Companies that have not respected the legal deadline of May 29 for the submission of annual financial statements risk fines that vary from several hundred to several thousand lei

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

In a global economic context marked by the intensification of efforts to combat tax evasion, Law no. 126/2024, introduces new measures aimed at strengthening the capacity of the Romanian tax authorities to react to such practices by companies

The authorities have again modified the legal operating framework of the national e-Transport system, this time through an already applicable emergency ordinance

Starting with May, 2024, companies must use a new model of the 112 form, after the National Tax Administration Agency updated the model form and its filling instructions

One of the major proposals of the World Bank for the reform of the tax system in Romania is a balancing of the taxation of wage incomes with the taxation of independent incomes

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

The grace period for e-Invoicing was extended until the end of May

The first CESOP reports, which must be sent to the tax authorities by the end of this month, will be made by the payment processors for the last hundred meters

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

After the onslaught of changes made to the tax legislation in the last months of last year, the authorities published another law in March that adds new provisions to the Tax Code

The Romanian authorities have launched a simplified application for issuing electronic invoices in XML format for micro-enterprises

More than 1,000 large companies will be tax reclassified, to be moved to the category of medium taxpayers starting from July 1

One of the conditions for the application of tax facilities in construction and the agri-food area is the share of the turnover from the activities specified in the Fiscal Code in the total turnover

ANAF aligns with global tax administration trends and introduces for the first time in Romania a new mechanism to increase the degree of voluntary compliance – horizontal monitoring

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

The fiscal policy regarding corporate income tax payers has changed substantially since this year, with important changes being introduced to the recovery of fiscal losses or the deductibility of some expenses

For all companies that have a general obligation to make SAF-T reports, the year 2024 also brings an additional obligation, which will have to be solved for the first time by most of them: the transmission of asset reports through the standard fiscal control file (Standard Audit File for Tax)

In the last weeks, the authorities have changed the framework for using the national electronic invoicing system several times

The tax changes issued at the end of last year by the Executive have brought changes on several levels, one of them being the tax facilities for sponsorships to NGOs

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

The Ministry of Finance has published the rules for submitting the annual financial statements for 2023

The authorities have approved the rules for the implementation of the e-Seal, the new national system designed to ensure the traceability of road transport of goods with customs or fiscal risk in Romania

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

The obligation to monitor road transport through the e-Transport IT system was extended at the end of last year

The document through which tax inspectors can verify the correctness of pricing for intra-group transactions is called the transfer pricing file

The legal framework for the implementation of DAC-7 was recently completed, after ANAF also published the form

The beginning of 2024 brings important changes in the tax legislation governing micro-enterprises

Form 112 has been amended by ANAF to reflect the new taxation rules to be applied from November to the taxation of salaries in IT, construction and the agri-food sector

Cabot Transfer Pricing wins an appeal against a 1 million lei tax decision received by a furniture manufacturer

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

The European Commission has proposed a new legislative framework for the harmonization of transfer pricing rules within the European Union

The monitoring of road transport will be done through an additional system, which will work in parallel with e-Transport

Starting from January 1, 2024, all companies in Romania will have to align themselves to a new tax administration standard: the electronic reporting of all invoices through the RO e-Factura system

The Ministry of Finance supplemented the general accounting regulations, as well as those aimed at non-profit organizations, through a recently published order

The Ministry of Finance has published an order updating the rules for the use and completion of the payment order for the State Treasury

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

The Romanian Customs Authority (AVR) recently published a new methodology for registration for customs purposes

The National Fiscal Administration Agency is moving forward with the secondary legislation necessary for the application of the European DAC-7 directive

Tax & Finance Forum organized by BusinessMark, addressed to both private and public sector companies, will take place on November 6 – 7, 2024

Tax offset is a process that allows companies to balance their tax liabilities with their claims to the state, bringing substantial cash-flow benefits for companies

Cabot Transfer Pricing became a member of AmCham Romania

ANAF has regulated a procedure necessary for companies that, after sponsoring within the maximum limit to which they are entitled, find that they must reduce their profit tax or microenterprise income tax

We are going through a period of challenges generated by the macroeconomic context and volatility, where the annual dynamics of the economy have slowed down, inflation rates are high, financing costs and interest rates are still high

The 18th edition of TaxEU Forum, the most important legislation and taxation event, will take place on 8-9 February 2024

Timely filing of accounting reports is not only a responsibility but also a legal obligation for companies

Financial Outcome. The closing of the 2023 financial year, IFRS issues and fiscal news for 2024

Alina Andrei, founder of Cabot Transfer Pricing and founder & trainer at Cabot School, spoke about Fiscal Controls in the field of transfer pricing

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

The Tax & Finance Forum will address the most important aspects and legislative news with fiscal impact, the main challenges for Romanian taxpayers and solutions to adapt to the new provisions

The impact of the events of recent years on the economic environment and on businesses is not easy to manage

The VAT return has recently been updated by the tax authority, and companies must submit the new model of the Form 300 starting with the related operations in August

The impact of the events of recent years on the economic environment and on businesses is not easy to manage

One of the many tax measures established last summer is that certain employer-provided benefits have preferential tax treatment only if, in total, they do not exceed a monthly ceiling of 33% of the basic salary

Clubantreprenor.ro organizes on Thursday, June 29, 2023 the conference with the theme “30 years of VAT in Romania”

The impact of the events of recent years on the economic environment and on businesses is not easy to manage

ANAF has modernized its approach to fiscal controls and aligned it with international trends

The impact of the events of recent years on the economic environment and on businesses is not easy to manage

The Tax & Finance Forum will address the most important aspects and legislative news with fiscal impact, the main challenges for Romanian taxpayers and solutions to adapt to the new provisions

A recently published law that has already entered into force clarifies the obligation to declare road transports of risky goods

The impact of the events of recent years on the economic environment and on businesses is not easy to manage

The 17th edition of TaxEU Forum, the most important legislation and taxation event, will take place on 9-10 February 2023 and will bring together specialists from the most important tax consulting companies

The Council of the European Union published in the Official Journal of the EU the Decision authorizing Romania to apply electronic invoicing at the national level for all invoices issued in B2B relations between taxable persons established on the national territory

Issued with a delay of almost two months, the procedure for applying the tax amnesty for gift vouchers has been published

The approximately 15,000 companies classified as medium taxpayers enter the last hundred meters with the implementation of SAF-T

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

A new type of tax reporting will enter into force starting in 2024, according to a European directive that is still waiting to be transposed into Romanian legislation

Toate companiile încadrate la categoria contribuabililor mari trebuie să își pregătească anual dosarul de prețuri de transfer

Cu rol mai degrabă punitiv până acum, inspecția fiscală a primit mai nou în procedura sa de derulare un pas premergător

ANAF a publicat o nouă procedură obligatorie de comunicare cu băncile prin aplicaţia e-Popriri, aplicabilă din 1 octombrie

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

It was approved and published in Official Gazette 1228/20.12.2022 – Law no. 370 for the approval of Government Ordinance no. 16/2022 for the amendment and completion of Law no. 227/2015 on the Fiscal Code

Among the important changes made to GO16 in Parliament is the postponement of the increase in property taxation until 2025

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

It is the budget season for the following year and large taxpayers are required to prepare their annual transfer pricing file (TPF).

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.