Major Tax And Procedural Changes In Romania

December 2025 – On 15 December 2025, the Romanian Parliament adopted Law no. 239, which will enter into force on 18 December 2025. The law introduces significant amendments to the Fiscal Procedure Code, the Fiscal Code, and other related regulations. The main changes are presented below:

Legislative updates regarding legal entities

• As of 1 January 2026, taxpayers which had in the previous year a turnover below EUR 50 mil. (note: those not subject to IMCA), incurring expenses related to intellectual property rights, management, advisory from non-resident affiliated parties, where such expenses exceeded 1% of the total expenses according to 2024 accounts, may deduct these expenses, in the current tax year (2025 and 2026), up to 1% of their total costs. Starting with 2027, the 1% threshold will be determined based on expenses reported in the tax return for the current tax year. These provisions do not apply to taxpayers holding an advance pricing agreement or to