Income from platforms, short-term lets, investments, shares received from an employer, contributions and returns. Analyses for the individual, not for the company.
Tax residence is not lost through absence but by completing a procedure and severing ties that the law lists exhaustively. Until then you remain taxable here on your worldwide income, and the administration learns what you have received abroad through the automatic exchange of information.
This section covers situations in which a tax obligation crosses a border: people working from Romania for foreign employers, Romanians who have relocated but keep ties here, investors holding accounts with foreign brokers, owners of property in other states, and companies moving their seat or their assets. The common thread is a costly misconception: the belief that tax paid in one state settles the obligation in the other. It does not; it changes only how much more you owe and under which mechanism, and filing generally remains compulsory.
It is addressed to individuals with income or assets in more than one jurisdiction and to companies with cross-border operations, and equally to advisers who need to test an existing structure before an inspection does. The analyses concentrate on what must be proved and when: the residence certificate at the time of payment, the documents supporting the foreign tax credit, and the forms and deadlines that turn a correct position into one that can be asserted against the authorities.
The material is grouped in three parts. Residence and double taxation deals with the fundamentals: the residence criteria and the departure questionnaire, how treaties operate and the tie-breaker cascade, and the position of those working from Romania for an employer who withholds nothing at source. Foreign income and assets covers the declaration and crediting of dividends, interest and investment gains, together with the treatment of property held abroad. Structures and reporting deals with relocating the company and the exit tax, and with the obligation to report cross-border arrangements.
ANAF's review of foreign accounts is dealt with at length in the tax inspection section, and the criminal consequences of undeclared accounts in the economic criminal law section.
Where you are taxable, and how a treaty applies in practice.
18 September 2026
One form, eleven income categories and two chapters with different logics. What is declared under each category, from independent activities and rent to investments and foreign income, where the logic breaks down for most people, namely the two separate contribution bases that are not added together, what the 2026 pre-filled return means and why it does not exempt you from liability, the 25 May deadline and the seven steps for filling it in.
18 September 2026
The special tax on high-value assets tripled on 1 January 2026, from 0.3% to 0.9%. It is due on residential buildings worth more than 2,500,000 lei, by individuals only, and on cars worth more than 375,000 lei, by individuals and companies alike, in each case only on the excess above the threshold. Two separate deadlines, 30 April and 31 December, the updated Form 216, and what ANAF does ex officio when you do not file.
18 September 2026
Since 2024 there have been two calculation bases and they are not added to each other. Independent activities owe CASS on actual net income, between 6 and 72 minimum wages, the upper cap having been raised in 2026. Rent, dividends, investments and the other income under Article 155(c) to (h) are aggregated with each other, in bands of 6, 12 and 24 minimum wages, but not with PFA income. The 2026 figures, the employee with additional income, CAS for the self-employed, optional cover, and the seven calculation steps.
18 September 2026
A plan meeting the definition in Article 7(39) of the Tax Code, including the minimum period of one year between grant and exercise, is taxed neither on grant nor on vesting, but only on sale, as investment income, on the whole appreciation from a nil base. A plan that does not meet it, with vesting under a year or settled in cash, is salary, with contributions. The four conditions, the three moments and the seven steps, including the account with the foreign broker.
18 September 2026
From 2026 the host's regime turns on a single number: up to 7 rooms, counted across all properties, the income is income from the use of property (cedarea folosinței bunurilor), with a 30% flat-rate deduction, that is 7% of gross; above 7 rooms it is an independent activity, with different contributions. The platform's commission does not form part of the income, the occupancy record is compulsory according to the ANAF guidance, short-term accommodation is not VAT exempt in the way ordinary letting is, and the platforms report under DAC7. The seven steps.
18 September 2026
Goods from personal property are sold free of tax under Article 62(m). Buying in order to resell is an economic activity. Platforms report under DAC7 those sellers with more than 30 transactions or more than EUR 2,000, and couriers report cash-on-delivery sums; these are reporting thresholds, not taxing thresholds. How ANAF tells a wardrobe from a shop, what the compliance notice means, and the seven steps, with or without one.
18 September 2026
What decides the matter is not the number of sales but continuity and the conduct of a trader. The implementing rules exclude the personal home and inherited goods, but treat more than one supply a year of other goods as an economic activity, and the CJEU, in Słaby and Kuć, settled the criterion of active steps to market the property. How reclassification appears in ANAF decisions, including for second-hand cars, why VAT and income tax operate on separate planes, and the seven steps.
18 September 2026
Two changes in opposite directions in 2026: persons invoicing under their personal numerical code were exempted from 1 June by Legea nr. 88/2026, before the obligation announced in January took effect, while the deadline for everyone else was shortened to five working days. PFA, individual enterprises and the liberal professions holding a tax code remain fully bound, B2B since 2024 and B2C since 2025, irrespective of VAT status. The two-question test, the penalties, including the invoice that ceases to be a supporting document, and the seven steps.
18 September 2026
Classification decides everything: an independent activity for any channel carried on with continuity, copyright income for works assigned, other sources only for an isolated collaboration. Products received are income in kind, payments from platforms established in other Member States require the special VAT code, and the platforms report under DAC7. What ANAF has already checked, and the seven steps, including regularising the past.
17 July 2026
Between July 2025 and May 2026 ANAF carried out 1,102 inspections of individuals, establishing additional liabilities of over 540 million lei. Where the line runs between occasional and economic activity, what obligations arise beyond it, the VAT threshold of 395,000 lei, and the compliance file that protects you retrospectively.
17 July 2026
If it fails to meet 4 of the 7 statutory criteria of independence, a PFA arrangement can be reclassified retrospectively as an employment relationship, with salary tax, CAS, CASS and penalties going back up to 5 years. Who is being targeted, what it costs, and how the defence is built.
17 July 2026
From 2026 crypto gains are taxed at 16%, and the platforms report transactions directly to ANAF (DAC8). How the tax and CASS are calculated, how to reconstruct your transaction history, and how to avoid treatment as unexplained income taxed at 70%.
17 July 2026
The thresholds of Legea nr. 70/2015 as it stands in 2026, the two channels through which banks report (ONPCSB and Article 61 of the Tax Procedure Code), how loans and gifts are properly documented, and why a perfectly lawful deposit can become income taxed at 70%.
Declaration, foreign tax credit and the treatment of property held abroad.
Relocating the company, and cross-border reporting obligations.
Informative material, updated on 18 July 2026. It does not constitute legal or tax advice; individual situations must be assessed on their own facts.
The 156 analyses are grouped into four areas. A real case usually passes through several of them.
Tax inspection, antifraud control and the review of an individual's tax position: from the compliance notice to the tax assessment decision.
38 analysesTaking ANAF to court: the action for annulment, suspension of enforcement, the evidence, the appeal on points of law and the recovery of sums paid.
12 analysesTax evasion, embezzlement, money laundering and the related economic offences: from the figure in the report to the defence in the file.
30 analysesEconomic substance, jurisdictions and anti-abuse rules: what remains lawful after BEPS, ATAD and CRS, and where the line into criminal liability is crossed.
10 analysesSeparating personal wealth from business risk: principles, liability, the instruments that actually protect, and the line between lawful planning and fraud.
10 analysesTrusts and the Romanian fiducie, family foundations, international succession and forced heirship: how wealth is transferred lawfully between generations.
7 analysesParty-appointed and out-of-court tax expertise: the technical challenge to the loss calculation in an inspection, in litigation and in the criminal file, from objections to counter-expertise.
20 analysesThe file and the methods, the comparability study, ANAF adjustments to the median, intra-group services and loans, APAs and the inspection, for transactions between related companies.
11 analysesThe complete list of the 156 analyses published, in chronological order, with filters by area.
Go to InsightsThe automatic exchange of information is already operating, and a correct but undocumented position is hard to defend retrospectively. A first conversation establishes where you are taxable and what has to be declared.