Companies required to hold a payment account in Romania from 2026; minimum turnover tax reduced

 The year 2026 brings fiscal changes for companies, among the most important being the reduction of the minimum turnover tax (IMCA) to 0.5 percent and a flat 1 percent tax rate for micro-enterprises.The IMCA was introduced through Law no. 296/2023 and applies to taxpayers with a turnover of over 50 million euros in the previous year whose profit tax is lower than the minimum 1 percent turnover tax. They are required to pay profit tax at the level of the minimum turnover tax.Moreover, from next year, companies will be required to hold a payment account in Romania or with the State Treasury for the entire duration of their activity. Newly established legal entities have 60 working days to open the account.If a taxpayer does not have a payment account in Romania or an account opened at a State Treasury unit or fails to submit annual financial statements within five months of the legal deadline, they will be declared inactive. Likewise, taxpayers who do not reactivate within one year from the date they were declared inactive or who have been inactive for more than three years at the entry into force of Law no. 239/2025 (Fiscal Code), will be dissolved.According to PwC consultants, Fiscal Package 2 also introduced other new cases for the dissolution of taxpayers/payers declared inactive. Thus, those without outstanding tax obligations, with budgetary claims for which enforcement titles have been issued but which are not subject to criminal investigations, will also be dissolved if they do not reactivate within 30 days from the entry into force of Law no. 239/2025.Furthermore, taxpayers who have been inactive between one and three years at the date of entry into force of the law, who have no outstanding tax obligations, with budgetary claims for which enforcement titles have been issued and are not subject to criminal investigations, will be dissolved if they do not reactivate within 90 days from the entry into force of this law.Next year, instalment payments will also be amended, introducing the obligation to present a surety contract."For legal entities, the surety contract must be concluded in authentic form with the real beneficiary/beneficiaries of the debtor. For individuals, the surety contract must be concluded under the provisions of the Civil Code, which means that the guarantor must be legally capable of assuming the obligation, must own sufficient assets in Romania in order to satisfy the claim and must reside in Romania. If any of these conditions are not met, the debtor must present another guarantor," PwC explained.Exempted from this rule are public institutions, autonomous public authorities/services, as well as legal entity debtors in which the state or an administrative-territorial unit/subdivision is the majority shareholder.For simplified instalment payments, maximum thresholds for debts apply. For individuals, the limit is 100,000 lei and for legal entities, 400,000 lei."This change aims to reduce the scope of simplified instalments by establishing upper thresholds for tax obligations that can be deferred under this scheme," PwC consultants explained.Moreover, a new condition requires that companies must be at least 12 months old from the date of establishment in order to submit a request.Fiscal Package 2 also provides for an increase in share capital for limited liability companies (SRLs). The share capital of SRLs will be set based on the net turnover from the annual financial statements of the previous financial year: 5,000 lei for SRLs with a net turnover above 400,000 lei or 500 lei for newly established SRLs and those with an annual net turnover up to 400,000 lei.Companies are required to increase their share capital by the end of the financial year following the one in which the net turnover exceeds the minimum threshold."In the case of a decrease in net turnover, the value of the share capital remains unchanged, except where the SRL is converted into a company of another form," a PwC release mentioned.