Practice area · 14 analyses

Romanians living abroad.

Tax residence, salary earned abroad, social contributions, pensions, accounts and property in another country. Analyses for those who live or work outside Romania and still have tax ties here.

Why this section

Leaving the country does not close the tax file.

Many Romanians who work or live in another country learn only from an ANAF notice that, for the Romanian tax authority, they are still resident here. The analyses in this section explain the rules that decide where and how much you owe, for those who live or earn money outside Romania.

The section brings together the issues that come up most often for Romanians abroad: tax residence and the departure questionnaire, salary earned abroad, social contributions when you work in another state, a pension received from abroad, foreign accounts and investments, property held in another state, and money sent or brought home.

The common thread is a widespread misconception: that once you have left, you no longer have obligations in Romania. Tax residence changes only under the conditions set by law, and ANAF automatically receives from other states information on the income and accounts of those it treats as residents.

The material is grouped in three parts: residence and leaving Romania, working abroad and money, accounts and property. If you have already received a notice or a tax assessment, your situation needs an individual review: see assistance for Romanians living abroad.

Residence and leaving Romania

Where you owe tax.

How tax residence is determined, what happens when two states treat you as resident and how double taxation is eliminated.

Tax residence in 2026: when you remain taxable in Romania although you have left

17 July 2026

Physically leaving Romania does not move your taxes: the criteria are alternative, and your domicile or centre of vital interests keep you resident even with minimal presence here. The Z017 questionnaire, the treaty's “tie-breaker” cascade and how ANAF checks through CRS/DAC2.

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Dual tax residence: when two states both treat you as resident, and how the conflict is resolved

18 September 2026

Both states claim tax on your worldwide income, each under its own law. The treaty resolves the conflict through criteria applied in strict order: permanent home, centre of vital interests, habitual abode, nationality and, as a last resort, agreement between the authorities. ANAF's questionnaires, the real role of the residence certificate and what happens when there is no treaty.

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Double taxation treaties: how they work in practice

17 July 2026

A treaty never applies “automatically”: without a residence certificate at the time of payment, the Romanian payer withholds the domestic rate of 16%. How it is applied, credit versus exemption, the withholding rates under major treaties, the principal purpose test (PPT) and the mutual agreement procedure.

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The mutual agreement procedure (MAP): how double taxation between states is eliminated, the three-year time limit, arbitration and what OG 11/2025 changed

18 September 2026

The administrative appeal and the court proceedings concern the Romanian act; the other state is not bound by them. For double taxation there is the mutual agreement procedure under Article 282 of the Tax Procedure Code, with ANAF as the competent authority, open since 2025 to any affected person, including pre-emptively, with a three-year time limit and with ANAF's power to depart from the inspection's findings. Directive 2017/1852 and the Arbitration Convention add deadlines and compulsory arbitration within the Union. The typical situations, coordination with the administrative appeal, and the seven steps.

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Working abroad

Salary, contributions and pensions.

The treatment of salary earned abroad, social contributions when you work in another state, and special situations.

Working abroad: do I still owe tax in Romania? The rule for salary, what must still be declared and what need not

18 September 2026

Salary paid by a non-resident employer for work carried out abroad is neither taxed nor declared in Romania, under Article 76(4)(o) and point 12(19) of the implementing rules. What still applies, though, is residence, which requires the declaration of your other worldwide income, the exception for secondment by a Romanian employer, contributions determined by the state of employment, and, on return, proof of the money brought home. The seven steps and the four costly assumptions.

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Form A1: in which state you pay contributions when you work in more than one country

18 September 2026

The A1 portable document establishes where social contributions are paid, not where income is taxed. The two regimes can, perfectly lawfully, point to different states. Who issues it, the three situations in which it is granted, the substantive conditions checked by CNPP, the seven steps to follow and what happens when it is missing.

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A seafarer paid by a foreign shipowner: where the contributions are paid and where the tax is

18 September 2026

A seafarer resident in Romania faces two separate questions. The flag of the vessel decides the contributions, under Article 11(4) of Regulation (EC) No 883/2004, subject to the exception for a payer in the state of residence. Residence and the treaty decide the tax, and Article 76(4)(o) of the Tax Code raises the problem of the high seas, which is not a foreign state. The seven steps and four typical combinations.

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Director of a foreign company, resident in Romania: where the remuneration is taxed

18 September 2026

A director's remuneration is income treated as salary and falls within the Romanian resident's worldwide income. The exclusion for work carried out abroad does not apply when management is exercised from Romania. But the question with the highest stakes is not the remuneration; it is the company: managed effectively from Romania, it risks becoming tax resident here. The three levels, in the right order, and the seven steps.

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Digital nomads and foreign salaries: where you owe tax and contributions

17 July 2026

Do you work from Romania for a foreign employer who withholds nothing? The absence of withholding at source is not an exemption; it shifts the obligation: a monthly D224 return for tax, and an agreement or the employer's registration for CAS and CASS. What Regulation (EC) No 883/2004 says, why the digital nomad visa does not concern you, and what the employer risks through a permanent establishment.

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Foreign pensions: what you owe in Romania in 2026, the 3,000 lei threshold, CASS and the treaties

18 September 2026

A pension received from another state is declared in Romania by the tax resident, through the Declarația unică, with 3,000 lei a month tax-free, tax of 10% and, from 1 August 2025, CASS of 10% on the amount above the threshold, calculated monthly, per country. The treaty decides whether the source state may withhold, distinguishing between public and private pensions, and the foreign tax credit is granted only for tax withheld lawfully. Residence on return, the reverse situation of the pensioner who has left, a worked example and the seven steps.

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Money, accounts and property

What ANAF learns without being told.

Foreign income and accounts, property held abroad and money sent or brought home.

Foreign dividends, interest and gains: declaration and the foreign tax credit

17 July 2026

From 2026, dividends are taxed at 16%, and gains made through brokers without a permanent establishment in Romania are also taxed at 16%, against 3% or 6% through resident intermediaries. How they are declared in the D212, how the foreign tax credit under Article 131 works, what documents it requires, which CASS thresholds apply and within what limits losses are carried forward.

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Foreign income and accounts: how the data reaches ANAF through CRS, and what you must declare

17 July 2026

Banks, brokers and fintechs in more than 100 jurisdictions report the balances and income of Romanian residents to ANAF every year. What the tax authority actually sees through CRS, what you declare in the Declaratia unica, how the foreign tax credit works, and what to do if you have received the notice about foreign income.

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Property held abroad: the tax obligations in Romania

17 July 2026

Paying tax there does not exempt you from declaring it here; it only changes how much more you pay, through the method set out in the treaty. Rent at the 20% flat-rate deduction, a sale taxed on the transaction price rather than on the gain, local taxes that are not credited, CASS by threshold and how ANAF finds out through DAC1 and DAC7.

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Cash and bank transfers in 2026: thresholds, reporting and what ANAF asks

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%.

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Informative material, updated on 3 October 2026. It does not constitute legal or tax advice; individual situations must be assessed on their own facts.

Assistance

Assistance for Romanians living abroad

Other areas

The other subject sections.

The 157 analyses are grouped into four areas. A real case usually passes through several of them.

International taxation

Tax residence, double taxation treaties, foreign income and property, exit tax and DAC6, for interests in more than one jurisdiction.

17 analyses

Tax inspection and the review of individuals

Tax inspection, antifraud control and the review of an individual's tax position: from the compliance notice to the tax assessment decision.

38 analyses

Tax litigation: taking ANAF to court

Taking 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 analyses

Economic criminal law: tax evasion, embezzlement, money laundering

Tax evasion, embezzlement, money laundering and the related economic offences: from the figure in the report to the defence in the file.

31 analyses

Offshore and international structures

Economic substance, jurisdictions and anti-abuse rules: what remains lawful after BEPS, ATAD and CRS, and where the line into criminal liability is crossed.

10 analyses

Asset protection

Separating personal wealth from business risk: principles, liability, the instruments that actually protect, and the line between lawful planning and fraud.

10 analyses

Trusts & Estates: succession and the transfer of wealth

Trusts and the Romanian fiducie, family foundations, international succession and forced heirship: how wealth is transferred lawfully between generations.

7 analyses

The party-appointed tax expert

Party-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 analyses

Transfer pricing

The 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 analyses

All analyses

The complete list of the 157 analyses published, in chronological order, with filters by area.

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