Analysis · International taxation · 17 July 2026

Foreign accounts and income: how data reaches ANAF through CRS — and what you must declare.

If you are Romanian tax resident and hold a bank account in Germany, a brokerage portfolio in the Netherlands, a Revolut account or dividends from an Italian company, the data already reaches ANAF — annually and automatically. Since 2017, Romania has received information under the Common Reporting Standard (CRS) from more than 100 jurisdictions, and since 2024 it has turned that data into systematic notification campaigns; the most recent wave was announced on 24 June 2026, for 2025 income. The real question is no longer whether ANAF learns of your foreign accounts, but what emerges when the data received is compared with what you declared in Romania. The good news: the obligations are manageable — provided you act before ANAF asks.

What ANAF sees

What actually reaches ANAF through CRS.

The Common Reporting Standard (CRS), developed by the OECD and applied in the EU through Directive 2014/107/EU (DAC2), requires financial institutions in participating states to identify their clients who are tax resident in other states and to report their data annually to their own tax authority, which transmits it to the state of residence. Romania ratified the multilateral agreement through Law no. 70/2016. For each reportable account of a Romanian resident, ANAF receives, in essence:

Full identification of the holder

Name, address, state of tax residence, tax identification number (for Romanians, usually the personal numeric code), date and place of birth.

The financial institution and account number

The bank, broker or fintech where the account is held, together with its identifier.

The balance at 31 December

The balance or value of the account at year-end — or the information that an account was closed during the year.

Gross interest received

The interest credited to the account during the reporting year, in gross amount.

Investment accounts

For custodial accounts: dividends, other income generated by the assets in the account, and gross proceeds from the sale or redemption of financial assets.

Not only the classic banks

Brokers, custodians, certain investment-linked insurance products and fintechs (Revolut, Wise, etc.) also fall under CRS, reporting from the jurisdiction in which they are authorised.

Two practical nuances. ANAF sees gross amounts, not your profit — if you sold shares worth EUR 80,000 with a real gain of 5,000, the figure visible through CRS is 80,000, and without a return and without documenting the acquisition cost it becomes the starting point of the discussion with the tax authority. And a given year's data reaches ANAF only after the Romanian annual return is due — which is why notifications typically arrive in summer or autumn, when returns are already overdue.

CRS is not the only channel: through DAC1, information on salaries, pensions and income from immovable property arrives from EU states, and from 2026 the DAC8 directive (transposed by Government Emergency Ordinance no. 71/2025) extends automatic reporting to crypto-asset platforms, with the first reporting in 2027.

The filing obligations

Which foreign income is declared — and how.

The basic rule is simple and often ignored: individuals who are tax resident in Romania owe tax on income from any source, in Romania and abroad (art. 59 and art. 130 of the Tax Code). The obligation exists even if the money never reaches Romania and even if the source state has already withheld tax.

Among others, the following are declared: interest, dividends, gains on securities through foreign intermediaries, rents from immovable property abroad, foreign pensions, income from independent activities and any other taxable income. The notable exception: salaries paid by a foreign employer for work actually performed abroad are not taxable in Romania and are not declared (art. 76(4)(o) of the Tax Code). If, however, you work remotely from Romania for a foreign employer, that income is, as a rule, taxable here.

Declaration is made through the single return (form 212), in the section for foreign income, separately for each country and source, by 25 May of the following year: 2025 income by 25 May 2026 (a deadline already passed, but a return filed now, on your own initiative, remains clearly preferable to one filed after a notification), 2026 income by 25 May 2027. Amounts in foreign currency are converted at the annual average exchange rate of the National Bank of Romania for the year the income arose. The rates for the most common foreign income:

  • foreign dividends: 10% for 2025 income; 16% for income obtained from 1 January 2026 (Law no. 141/2025);
  • interest: 10%, including in 2026;
  • gains on securities through intermediaries without a Romanian establishment: 10% on the annual net gain for 2025; 16% from 2026 (Law no. 239/2025) — with offsetting of losses within the same year and carry-forward of the net loss for 7 years, per country;
  • rents, pensions and the other categories follow their own rules.

In addition to tax, if your cumulative non-salary income (dividends, interest, gains, rents — domestic and foreign) exceeds 6 minimum gross salaries, you owe the health contribution (CASS) of 10% on brackets of 6, 12 and 24 minimum salaries: at the minimum salary of RON 4,050, thresholds of roughly RON 24,300, 48,600 and 97,200, with CASS of RON 2,430, 4,860 and 9,720 respectively.

A frequently requested clarification: tax legislation does not currently impose a separate declaration for the mere holding of a foreign account — tax obligations attach to the income generated. Separately from tax, there are statistical reports to the National Bank of Romania (NBR Regulation no. 4/2021), relevant in practice mainly for legal persons with accounts abroad and for long-term loans contracted with non-residents; if you are in such a situation, check the reporting obligations in force case by case.

Double taxation

The tax credit and the treaties: how you avoid double taxation.

The most widespread confusion: "I have already paid tax in Germany, so I have nothing left to do in Romania." Wrong — and exactly the confusion that generates the most notifications.

Romania has double taxation treaties with most relevant states. Depending on the treaty, double taxation is avoided through the tax credit method — the tax paid abroad is deducted from that due in Romania, but only up to the Romanian tax on that income (art. 131 of the Tax Code) — or through the exemption method. Essentially: the filing obligation remains in both cases, even if the final result is zero tax.

The credit is granted only if you can prove the actual payment of the tax abroad: through a document from the foreign tax authority, from the payer that withheld the tax at source (for example, the broker's tax report), or through a copy of the foreign tax return with proof of payment — and it is calculated per country and type of income. In practice: with a 15% withholding on dividends in the source state against 10% due in Romania (2025), you pay nothing more here, but the difference is not refunded; with a 5% withholding, you pay the difference. The detail that frequently surprises: CASS is not extinguished by the tax credit — it is due separately, in full, if you exceed the thresholds.

In practice, present to the foreign payer your Romanian tax residence certificate (for the reduced treaty rate from the moment of withholding) and systematically keep the foreign taxation documents — without them the credit is lost and the tax is paid twice. For taxes paid in states without a treaty with Romania, no credit is recognised.

The ANAF letter

The notification on foreign income: what it means and how you respond.

Since 2022, ANAF has run recurring campaigns notifying persons identified through the exchange of information as having undeclared foreign income, visibly intensified in 2024–2026. The most recent announcement dates from 24 June 2026: those who obtained undeclared foreign income in 2025 will receive notifications and will have the opportunity to clarify their tax situation before payment obligations are established. The first thing to understand: the letter is not a tax assessment and does not mean you automatically owe the amounts mentioned — it is an invitation to clarify and, handled correctly, often the last window in which the matter closes simply.

Step 01

Do not ignore it

Notifications are increasingly served through the Virtual Private Space (SPV), and time limits run whether or not you have read them.

Step 02

Reconcile the data

CRS information frequently contains distortions: gross amounts (not gains), joint accounts attributed in full to each co-holder, the same income reported by several institutions, own transfers that are not income. Confirm nothing before understanding what ANAF has and what is real.

Step 03

Gather the documents

Account statements, the broker's annual tax reports, withholding-tax certificates, the relevant contracts.

Step 04

Regularise, if appropriate

Form 212 or an amending return, with the correct calculation of the tax, of CASS and of the tax credit.

Step 05

Respond in writing, on time

A documented, professionally built response can close the subject without an audit.

If the notification goes unanswered, the tax authority can establish the tax of its own motion, exclusively on the figures received from the foreign administrations — gross amounts, with no acquisition costs and no tax credit — the result being, almost always, far higher than the real obligation. There is one more safety valve: filing the single return within 60 days of communication of the ex-officio decision leads to its annulment. And if you receive not a mere information letter but a compliance notice with a 30-day deadline — the formal step towards a personal tax situation check — the stakes rise significantly.

The negative scenario

Non-declaration and the road to the 70% tax.

At the base are the ancillary charges: interest of 0.02% per day and late-payment penalties of 0.01% per day, and for obligations established following checks — a non-declaration penalty of up to 0.08% per day. The fine for failing to file the return (RON 50–500) is negligible; that is not the problem.

The next step is the risk analysis: balances and turnovers seen through CRS without correspondingly declared income — the classic profile that triggers the personal tax situation check (verificarea situației fiscale personale, VSFP), activated when the difference between the income estimated by ANAF and that declared exceeds 10%, but at least RON 50,000. In the VSFP you may be asked for a statement of assets and income, and the period checked usually covers the 5-year limitation period. Amounts whose source cannot be justified are taxed at 70% — the rate applicable from 1 July 2024 to income from unidentified sources (Law no. 296/2023) — plus ancillary charges.

2026 brought an important acceleration: through Order of the President of ANAF no. 768/2026, in force from 6 July 2026, the VSFP can also be carried out by Antifraud inspectors, who can themselves issue tax assessments — a change analysed in our dedicated material. The road from CRS data to a decision in your name has shortened considerably.

At large amounts, the discussion goes beyond the fiscal sphere: systematic non-declaration can attract charges of tax evasion, and flows through foreign accounts — questions in the money-laundering area. In such files, the tax defence and the criminal defence must be coordinated from the first act.

Voluntary compliance

The concrete steps, before ANAF asks.

The difference between a manageable regularisation and an unjustified-income file is made, almost always, before the first letter. Concretely:

Step 01

Inventory everything you hold abroad

Bank accounts, brokers, fintechs, investment insurance, holdings — including accounts closed in recent years, which are also reported.

Step 02

Reconstruct the income of the last 5 years

Statements, annual reports, withholding-tax certificates — now, while the data is still easy to obtain.

Step 03

Calculate per year, country and source

With the correct method from the applicable treaty — tax credit or exemption — and with the CASS thresholds.

Step 04

File the returns on your own initiative

Form 212 or amending returns — and pay, or request instalments. A return filed before any notification keeps you in the regularisation-with-ancillary-charges zone, far from the logic of unjustified income.

Step 05

Keep the evidence file

Before a check, contemporaneous documents are worth incomparably more than later explanations.

Step 06

If the letter has already arrived

Do not answer on the first impulse: the deadline is sufficient for a documented response, and what you submit now becomes evidence in everything that follows.

CAUTION. Documents served through the Virtual Private Space (SPV) are deemed legally communicated when made available — even if you never opened them; check the SPV periodically, otherwise essential deadlines run without your knowledge. And do not try to "cover" undeclared amounts with documents created afterwards — backdated loans, accommodation receipts, fictitious gifts: such documents do not extinguish the tax problem, but can turn an administrative file into a criminal one.

Frequently asked questions

In brief, about foreign accounts.

I have an account with Revolut or an EU bank. Does ANAF learn of it?

Yes. Financial institutions, including fintechs, report the accounts of Romanian residents from the jurisdiction in which they are authorised, and the data — balance, interest, dividends, gross proceeds — reaches ANAF annually through CRS/DAC2.

I already paid tax in the state where I earned the income. Must I still declare in Romania?

Yes, the filing obligation remains. Through the treaty, the foreign tax is recognised as a tax credit (or the income is exempt), so that the amount payable is often zero — but CASS may be due separately, and non-declaration remains sanctionable even where the additional tax would have been nil.

I did not declare foreign income in past years. What can I do now?

You can file, on your own initiative, the single return or amending returns for the undeclared years, paying the tax and the ancillary charges. Before any notification it is a simple regularisation; afterwards, the margin narrows, and undocumented amounts risk the unjustified-income treatment. Each situation must, however, be assessed case by case before filing.

Must I declare to ANAF the mere fact that I have an account abroad?

There is no dedicated tax declaration for mere holding — the income generated is declared. The balance reaches ANAF anyway through CRS, so consistency between balances and your declared income matters.

Informational material, updated to 17 July 2026. It reflects the legislative position at the date of drafting; it does not constitute legal or tax advice and does not replace analysis of your specific situation.

Contact

Have you received a notice or an audit notification from ANAF?

Time limits run from the moment of communication. An initial discussion clarifies what is alleged, what you need to justify and how the defence is built — before an estimate becomes a tax assessment.

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