In a nutshell
Romania’s fiscal reforms applicable in 2026 introduce a complex mix of temporary relief measures and significant tax increases, driven by EU alignment requirements and domestic budgetary objectives. While the overall direction points toward an expanded tax base and increased fiscal pressure, transitional provisions create short- to medium-term planning opportunities.
These developments require companies to adopt more agile and forward-looking tax strategies, covering corporate income tax optimization, dividend policy adjustments, VAT cash-flow management, and group structuring. Proactive analysis and timely implementation will be key to transforming regulatory change into a competitive advantage.
Corporate income tax: a transitional window for optimization
For large taxpayers, the minimum tax on turnover (IMCA) is reduced to 0.5% in 2026 and is scheduled to be fully eliminated starting 2027. This transitional period allows companies to reassess their tax position, focusing on maximizing deductible expenses, revisiting provisioning policies, and timing investments in a manner that efficiently manages the taxable base.
In the extractive sector (oil & gas), the additional turnover tax (ICAS) remains applicable until the end of 2026 and is repealed from 2027. This evolution may justify a reassessment of ongoing commercial arrangements and long-term contractual pricing mechanisms.
In contrast, the banking sector continues to face sustained fiscal pressure, as the turnover tax remains set at 4% (or 2% for institutions with a market share below 0.2%), maintaining pressure on profitability margins.
At the same time, the elimination of the tax on income obtained by affiliates reflects Romania’s efforts to align more closely with OECD standards, potentially impacting group structures and intragroup transactions.
Micro-enterprise regime: fewer beneficiaries, clearer choices
The micro-enterprise regime undergoes significant changes, with the revenue threshold reduced to the equivalent of EUR 100,000. As a result, a considerable number of companies will transition to the standard 16% corporate income tax regime.
Nevertheless, the 1% tax on total revenues remains attractive for businesses with low cost structures, particularly in services and small-scale trading activities. Companies should reassess their revenue mix and operational structure and, where commercially feasible, evaluate restructuring or outsourcing options to remain eligible for the micro-enterprise regime.
VAT changes: pricing and cash-flow considerations
Starting August 2025, the standard VAT rate increases to 21%, while reduced rates are unified at 11%, with a direct impact on pricing strategies and cash-flow planning in 2026.
At the same time, the VAT exemption threshold increases to RON 395,000, offering tangible relief for small businesses. In parallel, a fixed RON 25 charge is introduced for non-EU parcels with a value below EUR 150, a measure likely to affect e-commerce business models.
Against this backdrop, companies are advised to review supply chains, reassess contractual pricing, and ensure optimal recovery of deductible VAT.
Dividend taxation and investment strategy
From 2026, the dividend tax increases to 16%, significantly reducing the attractiveness of profit distributions. The same rate applies to certain benefits granted to shareholders, gains from unlisted securities, and cryptocurrency transfers, subject to limited exemptions for annual gains below RON 600.
By contrast, gains derived from listed securities benefit from differentiated rates: 3% for long-term holdings and 6% for short-term holdings.
In this context, companies may consider prioritizing profit reinvestment, reassessing holding structures, and making effective use of double taxation treaties to mitigate the overall tax burden.
Social contributions and sector-specific taxes
Additional pressure arises from changes to social contributions. For self-employed individuals, the health contribution (CASS) ceiling increases to 72 gross minimum wages. Pension income exceeding RON 3,000 per month becomes subject to a 10% health contribution, applied only to the excess amount.
The specific tax on constructions remains applicable in 2026 and is repealed from 2027, creating a limited planning window for capital-intensive projects in industrial and construction-related sectors.
Procedural and corporate law considerations
From a procedural perspective, Romanian Companies Law imposes stricter restrictions: companies cannot grant shareholder loans until any differences arising from dividend distributions have been fully regularized, in accordance with accounting standards and applicable legal requirements. Dividend distributions are prohibited where companies record accounting losses or where net assets fall below the statutory minimum share capital.
In situations involving net asset erosion, companies may consider the capitalization of shareholder loans as a means to strengthen their balance sheet and restore compliance.
In addition, advance pricing agreements (APAs) may be applied retroactively for up to five years, while mutual agreement procedures for resolving double taxation disputes are increasingly aligned with OECD best practices.
Looking ahead
The 2026 fiscal reforms provide increased predictability in the medium to long term but require immediate and proactive action. Companies are encouraged to perform detailed fiscal impact simulations, revisit group and financing structures, and actively manage liquidity to transform regulatory challenges into competitive advantages.
Written by: Elena Malos, Senior Manager,
Tax Consulting and Compliance Services, Baker Tilly Romania
