You work on a building site in the Paris region, in winegrowing, in care or in restaurants, under a French contract, and your tax is withheld monthly, at source. If your identity card still shows your Romanian address, ANAF, Romania’s national tax administration, may continue to regard you as a Romanian tax resident and may claim tax on income on which you have already paid tax in France.
Under Article 76(4)(o) of the Tax Code, salary received for work actually performed in France and paid by a French employer is not taxable in Romania and is not declared here.
There are two conditions and both must be met: the work is physically performed in France, and the payer is a non-resident employer. The situation becomes more complicated for those posted by a Romanian company to French building sites. They are paid from Romania, so the exemption does not apply in the same form, and the tax is allocated between the two states under the double tax treaty.
ANAF does not start from your contract. It starts from the data received automatically from France and from your domicile in Romania. The result may be a notice or a tax assessment decision (decizie de impunere) for income tax and, sometimes, for CAS (the state pension contribution) and CASS (the health insurance contribution). Such a decision does not become final if it is challenged in time, by administrative appeal (contestație), and with evidence.
It is a common misconception that the Romanian tax authorities do not know what a Romanian earns abroad. Between EU Member States, tax administrations automatically exchange, year after year, information on salaries, directors’ fees, life insurance and immovable property, under Directive 2011/16/EU (DAC1). The French tax administration (DGFiP) therefore sends Bucharest data on the income of people whose address is recorded in Romania.
On top of this comes the OECD Common Reporting Standard (CRS): banks in more than 100 jurisdictions report the accounts of non-residents, with balances, interest, dividends and sale proceeds. In 2022, data on 111 million accounts was exchanged through this mechanism. Digital platforms report sellers’ income (DAC7), and from 2026 data on crypto-assets is also collected (DAC8).
Nobody needs to request this data. It reaches ANAF automatically, and ANAF compares it with its own records. If your domicile is recorded in Romania and there is no explanation for your income from France, the system generates a notice.
Since 2019, France has withheld income tax monthly, at source (prélèvement à la source), so a good part of the evidence already exists on your payslips. What matters is that you keep them for each year.
Monthly payslips. They show the employer, the period worked, the social contributions and the tax withheld at source.
The annual income tax return filed in France, usually online, on impots.gouv.fr. It shows that France treated you as a French tax resident.
The annual tax assessment issued by the French tax administration after the return. It is the main evidence of the tax paid in France.
The certificate of French tax residence, issued on request by the tax office. It is the document that carries the most weight before ANAF when residence is in dispute.
Your career and pension contribution record in France, obtained from your Assurance retraite account. It answers claims for CAS in Romania for the same years.
Proof that you are insured in the French health system. It answers claims for CASS for the same period.
The French General Tax Code (Article 4 B) regards as a tax resident a person whose family home or principal place of stay is in France, a person who carries on their main professional activity there and a person whose centre of economic interests is in France. One of these criteria is sufficient. Romania regards you as resident if you keep your domicile or your centre of vital interests here (Article 7(28) of the Tax Code).
This is how it often happens that both states regard you as resident. The double tax treaty between Romania and France, in force since 1975, then decides through its tie-breaker rules: permanent home, centre of vital interests, habitual abode, nationality. Someone whose family and home are in France has good arguments. Someone whose family is in Romania, with only a job and a rented room in France, needs a more careful analysis.
For employees within the European Union, Regulation (EC) No 883/2004 applies the social security legislation of the state in which the work is performed. The contributions withheld in France cover pension and health insurance, and no CAS or CASS is due in Romania on the same salary.
Posting is the exception. A worker sent to France by a Romanian company, with the A1 document, remains in the Romanian social security system, and contributions are paid in Romania. For posted workers, the first thing to check is whether an A1 was issued and for what period.
ANAF’s right to assess taxes is, as a rule, time-barred after 5 years, counted from 1 July of the year following the year for which the tax is due (Article 110 of the Tax Procedure Code). Where the obligation arises from acts that constitute criminal offences, the law provides for a 10-year period.
The decision may include income tax and social contributions, calculated as if the income had been earned in Romania, without automatically taking into account the tax and contributions paid in France. What was paid there must be proved.
Interest and late-payment penalties are added for every day from the due date until payment, so the amount grows with each year reviewed.
A decision that is not appealed in time can be enforced, including by garnishment (poprire) of accounts in Romania and by measures against assets held here.
When you buy a house or make large deposits into an account, savings from France may be treated as unjustified income, taxable at 70%, if their origin is not proved.
I work with Romanians in France without their having to come to Romania. The legal assistance agreement is signed remotely. Under a lawyer’s power of attorney (împuternicire avocațială), I represent you before ANAF and, where necessary, before the Romanian courts.
We talk by telephone, on WhatsApp or by video call, in real time. Documents are sent scanned or photographed. You download the French ones from your account on impots.gouv.fr or from your Assurance retraite account, and I tell you which of them are needed for each year.
I carry out the analysis as a lawyer, tax adviser and forensic tax expert, so the legal argument and the figures are checked together before any reply is sent to ANAF.
No. Salary paid by a French employer for work in France is neither taxed nor declared in Romania (Article 76(4)(o) of the Tax Code). Keep your contract, your payslips and the avis d’impôt for each year.
Your salary is paid from Romania, so the exemption for non-resident employers does not apply in the same form. The tax is allocated between the two states under the Romania-France double tax treaty, and contributions usually remain in Romania, on the basis of the A1 document.
Do not ignore it and do not pay before an analysis. The decision can be appealed only within a limited period, and the arguments are built on the French documents and the treaty. Send me the decision and I will tell you on what grounds it can be appealed.
Not on the same salary: contributions are due in the state in which you work, under Regulation (EC) No 883/2004. If ANAF nevertheless issues a decision, it is appealed with the relevé de carrière and proof of health insurance in France.
Yes. The engagement is signed remotely, I represent you before ANAF and the Romanian courts under a lawyer’s power of attorney (împuternicire avocațială), and we communicate by telephone, on WhatsApp or by video call.
Information material, updated on 3 October 2026. It does not constitute legal or tax advice; individual situations must be analysed on their own facts.
The analyses for Romanians who have moved abroad are grouped in the section Romanians living abroad, where you will also find all the countries. The general rule for salary income is explained in Working abroad, and for a specific situation see assistance for Romanians living abroad.
Italy, Germany, Spain, the United Kingdom, France, Austria, Belgium, the Netherlands, Ireland, Denmark, Sweden, the United States and Canada, the United Arab Emirates and offshore companies.
See all countriesSalary paid by a Belgian employer for work performed in Belgium is not taxed in Romania. Posted workers and the self-employed are subject to different rules. Fiche 281.10, the avertissement-extrait de rôle and a defence conducted remotely.
Read the analysisSalary paid by an Italian employer for work performed in Italy is not taxed in Romania, but ANAF can issue decisions covering the last 5 years. The Italian documents that matter and a defence conducted remotely.
Read the analysisSalary paid by a Spanish employer for work performed in Spain is not taxed in Romania, but ANAF can issue decisions covering the last 5 years. Certificado de residencia fiscal, vida laboral and a defence conducted remotely.
Read the analysisSend me the document on WhatsApp or by e-mail. An initial analysis shows whether the decision can be challenged and which French documents are needed.