Romanian taxation is undergoing a period of accelerated reform, with a profound impact on the business environment. The year 2025 is marked by intensified tax audits, the expansion of digitalization, and the introduction of legislative changes that increase pressure on companies.

Accelerated increase in tax audits, between prevention and sanction

The trend observed by Cabot specialists in recent years regarding the intensification of tax audits has also been confirmed in 2025. According to the Performance Report published by ANAF, in 2024 over 21,000 tax inspections were carried out, 2.8% more than in 2023. Approximately 75% of these targeted legal entities, while 25% were directed at individuals.

The additional tax liabilities imposed on taxpayers following these inspections amounted to 5.56 billion lei, almost double compared to the previous year. It is important to highlight that 98% of this amount was imposed on companies, which reconfirms that the business environment is under strict and constant fiscal monitoring.

Audits are no longer isolated events or reserved for “large taxpayers”—they target the entire business spectrum: logistics, services, manufacturing, retail, construction, IT, and many others.

Desk audits, ANAF’s preferred instrument

A clear trend in 2024, continuing into 2025, is the expansion of desk audits. According to ANAF data, over 29,000 such audits were conducted, an increase of approximately 45% compared to 2023. Of these, 21,000 targeted companies, and 8,000 targeted individuals.

Interestingly, in 2024, ANAF collected 459.87 billion lei for the state budget, almost 19% more than in 2023. This increase is significant in nominal terms—revenues were 72.99 billion lei higher than the 386.88 billion lei collected in 2023. In addition, the institution achieved a revenue collection target rate of 99.29%, thus approaching the target set for 2023.

Desk audits are becoming more frequent and may serve as a prelude to a full inspection, especially when discrepancies arise between reported data and those identified by ANAF through interconnected information sources.

Fiscal digitalization, a catalyst for change

The digitalization of the taxpayer-ANAF relationship has accelerated significantly in recent years, but in 2024 and 2025 we have witnessed the maturation of this process. SAF-T (D406) has become mandatory even for small taxpayers, the e-Invoice system has expanded to B2C transactions, and the e-VAT system adds a new layer of complexity to tax reporting.

For authorities, the benefits are clear: centralized, real-time access to accounting and tax data, with the ability to automatically identify discrepancies and initiate targeted audits. For taxpayers, however, this process involves significant investments in IT infrastructure, updating internal procedures, and staff training.

Errors or omissions in tax reporting can no longer go unnoticed, and every unexplained discrepancy may trigger a request for clarification, a desk audit, or even a full tax inspection.

Transfer pricing, under the authorities’ scrutiny

One area where Cabot has solid expertise is transfer pricing, a topic increasingly in the focus of tax inspectors. We have seen a significant increase in requests from companies regarding:

• preparation of the transfer pricing file;

• assistance during tax audits;

• responses to requests from authorities regarding price adjustments, VAT deductions, or missing supporting documentation.

In many cases, the transfer pricing file has become a prerequisite for VAT refunds, highlighting the importance of robust and up-to-date documentation.

The 2025 tax changes, broad and immediate impact

The year 2025 began with a series of tax changes directly affecting companies in Romania:

• reduction of the turnover threshold for micro-enterprises from EUR 500,000 to EUR 250,000, with a further planned decrease to EUR 100,000 starting in 2026;

• increase of the dividend tax rate from 8% to 10%;

• elimination of tax incentives for employees in IT, construction, agriculture, and the food industry;

• introduction of the construction tax (“pillar tax”) of 0.5%, or 0.25% for constructions owned by the state;

• implementation of global minimum tax legislation, targeting corporate groups with global revenues exceeding EUR 750 million.

SMEs are particularly exposed to high risk, as exceeding the micro-enterprise threshold involves higher costs for accounting and tax reporting, as well as corporate tax payments.

Global minimum tax, a new regulation with complex implications

In 2025, Romanian companies that are part of large multinational groups are affected for the first time by the implementation of global minimum tax legislation. This involves calculating an additional tax due for 2024, based on consolidated or individual financial statements, with a payment deadline of June 30, 2026.

This regulation aims to ensure a minimum effective tax rate for large international companies and requires a major shift in their tax approach. Moreover, it involves complex analyses and close collaboration between accounting, tax, and legal teams.

Looking ahead, what should businesses expect?

With a new government on the horizon, 2025 is expected to bring even more tax changes. Signals point to increasing fiscal pressure, with a focus on digitalization, compliance, and efficient revenue collection.

ANAF will continue investing in database integration and the use of artificial intelligence to identify high-risk taxpayers. Audits will become more targeted, faster, and harder to contest.

Cabot Transfer Pricing provides essential support for companies seeking to navigate today’s tax challenges effectively. With a team of consultants specialized in transfer pricing, taxation, and accounting, Cabot is a trusted partner in preparing tax documentation, during inspections, and in ensuring compliance.

Contact us for a personalized analysis of your tax risks and to determine how we can support you in managing the challenges brought by the new tax landscape: https://cabot-tp.ro/en/contact/