Finance Ministry unveils new fiscal reform package targeting multinationals, non-EU deliveries, tax compliance

The Romanian Finance Ministry has published the second package of fiscal reform measures for public consultation, with Finance Minister Alexandru Nazare announcing a shift in approach towards multinational companies, new taxation on non-EU parcels, and tighter rules on debt collection and corporate compliance.   The reforms come amid slowing economic growth, a 30% drop in foreign direct investment in the first five months of the year, and mounting concerns over Romania’s budget deficit and revenue losses from tax evasion. Nazare said the new measures aim to stimulate investment while ensuring that both multinational corporations and online sellers from outside the EU contribute fairly to the tax base.   Tax on affiliated transactions for multinationals Nazare said the current turnover tax for companies with revenues over EUR 50 million will be replaced in 2026 with a targeted levy on transactions with affiliated entities. The measure focuses on four expense categories often used to transfer profits abroad: management fees, administrative costs, intellectual property rights, intra-group interest and consultancy. Only expenses up to 3% of turnover will remain deductible, with amounts exceeding this threshold taxed at 16%. The government expects RON 8.5–10 billion in additional profit tax revenue.   RON 25 tax on non-EU parcels To address a surge in low-value non-EU imports, such as those from Shein and Temu, a fixed tax of RON 25 will be applied to parcels worth up to EUR 150. The tax, expected to raise around RON 1.3 billion annually, will be implemented with courier companies to cover both direct and indirect imports. Companies establishing logistics hubs in Romania will be exempt.   Strengthening ANAF coordination and integrity The reform would formalise the Ministry of Finance’s coordination role over ANAF in specific activities, while leaving control functions to the tax authority. Integrity tests will be introduced for ANAF, the Customs Authority and the National Gambling Office, alongside bodycams for inspectors to improve transparency.   Tighter rules on debt rescheduling The simplified debt rescheduling scheme, introduced during the pandemic, will be overhauled to prevent abuse. Companies seeking rescheduling will need to provide guarantees, deadlines will be cut from 180 to 60 days, and a contract of surety will be required.   Preventing transfer of debt-laden companies Selling shares in indebted companies to avoid tax liabilities will be criminalised. Transactions will require proof of payment or guarantees for outstanding debts.   Corporate compliance measures All companies will be required to hold a bank account. The minimum share capital for limited liability companies will be increased from RON 200 to RON 8,000, adjusted for inflation since the 1990s. The reform also removes the RON 50,000 threshold for mandatory card payments — all merchants must offer both cash and electronic payment options.   Addressing inactive companies Romania has over 462,000 inactive companies owing RON 3.5 billion. The Ministry aims to simplify dissolution procedures and reduce the administrative burden they create.   Nazare linked these measures to the need to encourage investment, prepare for possible economic slowdown, and address revenue losses from tax evasion and non-EU imports. He also criticised the previous turnover tax’s limited results, noting it raised just RON 1.2 billion versus an expected RON 5–7 billion.