On August 29, 2025 Romania’s Official Gazette published Ordinance No. 21, amending Law No. 431/2023 on global minimum taxation under OECD Pillar Two. The changes include counting qualified refundable and transferable tax credits as income when calculating a group entity’s profit or loss and adjusting how the national additional tax is computed. Entities may carry forward negative amounts of additional taxes under certain conditions. If an entity meets safe harbor and penalty relief criteria, its additional tax liability can be set at zero. The ordinance also sets an 18-month deadline after the reporting year’s end for filing returns and paying additional tax. It takes effect September 1.
To read more on the Ordinance, click here.
On July 24, 2025 the Official Gazette of Romania published Ordinance No. 11, which updated rules related to advance pricing agreements (APAs) and mutual agreement procedures (MAP). The new rules for APAs allow to be applied retroactively for five fiscal years, additional six months to suspend tax audits, unless related to applied agreements. The ordinance established procedures for tax ruling implementations and APA processes, with MAP processes refined to comply with EU Directive 2017/1852 and the Convention on the elimination of double taxation. The ordinance established a three (3) year limitation for raising disputes using the MAPs and sets unilateral a limitation of three (3) years, on tax treaty provisions that express a shorter limitation for raising disputes. The Changes take effect on July 27.
Ordinance can be accessed here.
On July 24, 2025 the Romanian government approved an ordinance enabling advance pricing agreements (APAs) to permit retroactivity for transactions over a period of up to five years. In order to qualify, past and future transactions must be comparable. The ordinance aims to bring APAs to the front of tax audit lanes for the same tax reporting periods to improve efficiency. Additionally, the mutual agreement procedure for resolving double taxation was updated to align with OECD guidelines and reflect Romania’s commitment to strengthen its international tax legitimacy.