Romanian law exempts, under certain conditions, salary earned outside the country. ANAF increasingly questions precisely those conditions: who pays you, where you actually worked and which state treats you as tax resident. What stands between a tax assessment and a resolved file is the evidence and the way it is argued.
The legal services described on this page are provided by Florin Hrițuliac, avocat of the Brașov Bar, acting for his own clients; the work is carried out through Cabinet de avocat Mihai Guran. This page is informative.
About the attorney →You have received a notice or a tax assessment from ANAF for income earned abroad, based on data sent automatically by other countries’ tax authorities.
You have lived and worked in another country for years, yet ANAF’s records still show you as a Romanian tax resident, taxable on your worldwide income.
Your foreign salary has been treated as taxable in Romania, for instance because your employer, your contract or the place where you worked was read differently from how you understood it.
You work from Romania for a foreign company, you are self-employed or freelancing in another country, or you earn income through platforms. The rules differ from those for an ordinary salary.
You have bought a home or paid into a Romanian account the money saved over years of work abroad, and ANAF is asking you to justify where it came from.
You own a let property, accounts or investments in another country and it is unclear what had to be declared in Romania.
ANAF automatically receives from other countries’ tax authorities information on the income, accounts and assets of people it treats as Romanian tax residents. On 24 June 2026 ANAF announced notices to individuals who had not declared their foreign income for 2025.
Leaving Romania does not, by itself, change your tax residence. The Fiscal Code treats as a Romanian tax resident anyone whose domicile or centre of vital interests is in Romania, or who spends more than 183 days here in any 12-month period (art. 7 point 28). A person who left without completing the departure formalities remains, in ANAF’s records, a Romanian resident.
Salary earned abroad is excluded from Romanian tax only if the work is actually performed in another state and the salary is paid by a non-resident employer (art. 76(4)(o) of the Fiscal Code). Where ANAF questions either condition, the salary may end up being taxed in Romania.
For gaps between a person’s assets and the income known to ANAF, the law provides for a 70% tax on income considered unjustified. A foreign salary does not appear in Romanian returns, so savings from years of work abroad may look, on paper, unexplained.
Tax residence and a state’s right to tax you are decided on evidence and on the double tax treaty between Romania and the country where you work. What matters is which documents exist, how they fit together and how they are presented.
A tax assessment can be challenged only within a limited period, and arguments not raised in time are lost. The amount assessed can be enforced, including by garnishing Romanian bank accounts, and without a timely challenge the assessment becomes final.
A hasty reply to an ANAF notice, given without analysing your situation, may later be used against you.
Where the amounts are large or ANAF suspects concealed income, a tax file can turn into a criminal investigation. The defence has to be planned on both fronts from day one.
I am an attorney at the Brașov Bar, a tax adviser registered with the Romanian Chamber of Tax Advisers (no. 8191) and a forensic tax expert authorised by the Romanian Ministry of Justice. I look at your situation from all three angles, legal, tax and technical, and represent you before ANAF and, where necessary, in court.
I work with clients across Romania and in the Romanian diaspora. Consultations take place at the Brașov office, by phone or by video call, in Romanian or English. Documents can be sent electronically; you do not need to travel to Romania.
For a first conversation it helps to have to hand the ANAF notice or assessment, your employment contracts abroad and any document showing where you live and where you pay tax.
ANAF works with data received automatically from other countries and on the presumption that you are still a Romanian tax resident. The exclusion of a foreign salary depends on precise conditions, and if your file does not prove them, ANAF may treat the salary as taxable income. Such an assessment may be wrong, but it has to be challenged in time and with evidence.
Not necessarily. The missing questionnaire does not automatically make you a Romanian resident, but it leaves you recorded as one in ANAF’s files, and in practice the burden of proving otherwise falls on you. The answer depends on the Fiscal Code criteria and on the treaty between Romania and the country where you live.
Yes. Consultations take place by video call or by phone, in Romanian or English, and documents are sent electronically. Representation before ANAF does not require you to be in Romania.
ANAF may assess the tax of its own motion, with late-payment interest and penalties, and the amount can then be enforced, including from Romanian bank accounts. Not replying does not stop the procedure.
Tax residence and leaving Romania, salary earned abroad, contributions, pensions, accounts, property and money brought home.
14 analysesThe rule for salary, and what still has to be declared.
Read the analysisWhen you remain taxable in Romania although you have left.
Read the analysisWhen two states treat you as resident and how the tie is broken.
Read the analysisDeclaring foreign income and the foreign tax credit.
Read the analysisA timely review shows whether the assessment can be challenged, on what grounds and what must be protected straight away.