You work in construction in Dublin, in food processing, on farms, in hotels or in care, with a PPS number and with tax withheld through PAYE. Some have been in Ireland for ten years, others come for a season. For ANAF, Romania’s national tax administration, the question is whether you have remained a Romanian tax resident, and the Irish data reaches Bucharest in any case.
Under Article 76(4)(o) of the Tax Code, salary received for work actually performed in Ireland and paid by an Irish employer is not taxable in Romania and is not declared here.
There are two conditions: the work is physically performed in Ireland, and the payer is a non-resident employer. Income earned in Ireland as self-employed, for example in construction, is, however, income from independent activities. If you remain a Romanian tax resident, this income is declared in Romania, and the treaty determines how the Irish tax is taken into account.
ANAF starts from the data received automatically from Ireland and from your domicile in Romania. The result may be a notice or a decision for income tax and, sometimes, for CAS, the state pension contribution, and CASS, the health insurance contribution. A decision that is appealed in time and with evidence does not become final.
It is a common misconception that the Romanian tax authorities do not know what a Romanian earns abroad. Between the Member States of the Union, tax administrations automatically exchange, year after year, information on salaries, directors’ fees, life insurance and immovable property, under Directive 2011/16/EU (DAC1). The Irish tax administration (Revenue) thus sends to Bucharest data on the income of persons registered with an address 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).
No one has to request this data. It reaches ANAF automatically, and ANAF compares it with its own records. If you are registered with a domicile in Romania and there is no explanation for your income from Ireland, the system generates a notice.
Almost all of them can be found in your Revenue myAccount or in MyWelfare. The Irish tax year is the calendar year, as in Romania, which makes the calculations easier.
The annual statement of salary and tax withheld, generated by Revenue from the employer’s reports. Since 2019 it has replaced the P60, and it is the main evidence for salary.
Payslips. They show the employer, the period worked and the PAYE, USC and PRSI deductions.
The annual calculation of the tax due in Ireland, after the end-of-year review. It confirms the tax assessed.
The Irish certificate of tax residence, requested through myAccount. It is the document that matters most when ANAF disputes your residence.
For those who work as self-employed: the annual return and the Irish tax assessment decision, as evidence of the tax paid on independent income.
The record of social contributions in Ireland, from the Department of Social Protection, through MyWelfare. It answers claims for CAS or CASS in Romania.
Ireland treats as tax resident a person who spends at least 183 days there in a year, or at least 280 days over two consecutive years, provided that more than 30 days were spent there in the year under review. Romania considers you resident if you keep your domicile or the centre of your vital interests here (Article 7(28) of the Tax Code).
When both states consider you resident, the double tax treaty between Romania and Ireland, applicable since 2001, decides through its tie-breaker criteria: permanent home, centre of vital interests, habitual abode, nationality. Those who have their family and home in Ireland have good arguments; those whose family is in Romania need a more careful analysis.
Regulation (EC) No 883/2004 applies the social security legislation of the state in which the work is performed. PRSI contributions paid in Ireland cover the pension and social benefits, and no CAS or CASS is owed in Romania on the same salary.
USC, the Universal Social Charge, is a tax in Ireland, not a social contribution. The distinction matters when the foreign tax credit is calculated for independent income declared in Romania. For workers posted by Romanian companies, with the A1 document, contributions remain in Romania.
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 Ireland. What was paid there must be proven.
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 Ireland may be treated as unjustified income, taxable at 70%, if their source is not proven.
I work with Romanians in Ireland without their having to travel to Romania. The legal assistance agreement is signed remotely. Under a lawyer’s power of attorney (împuternicire avocațială), I represent you before ANAF and, if necessary, before the Romanian courts.
We talk by telephone, on WhatsApp or by video call, in real time, in Romanian or in English. You download the Irish documents from myAccount and MyWelfare; I will tell you exactly which ones are needed for each year.
I carry out the analysis as a lawyer, tax adviser and forensic tax expert, including the calculation of the foreign tax credit for self-employed income, which is where mistakes are most often made.
No. Salary paid by an Irish employer for work in Ireland is not declared and is not taxed in Romania (Article 76(4)(o) of the Tax Code). Keep your Employment Detail Summary for each year.
If you are a Romanian tax resident, as a rule, yes: independent income from Ireland is declared in Romania, with a credit for the Irish tax, under the terms of the treaty. If your residence has moved to Ireland, the obligation disappears.
USC is an Irish tax, separate from income tax. For independent income declared in Romania, it counts in the calculation of the foreign tax credit, under the terms of the treaty.
Do not ignore it, and do not pay before it has been analysed. The decision is appealed within a limited period, with the Irish documents. Send me the decision and I will tell you on what grounds it can be appealed.
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 British employer for work performed in the United Kingdom is not taxed in Romania, but self-employed income is treated differently. The new 2026 tax treaty, P60, SA302 and a defence conducted remotely.
Read the analysisSalary paid by a Dutch employer or a temporary employment agency for work performed in the Netherlands is not taxed in Romania. Jaaropgaaf, aanslag, BRP or RNI and a defence conducted remotely.
Read the analysisSalary paid by an American or Canadian employer for work performed there is not taxed in Romania. W-2, T4, the tax treaties, FATCA and the social security agreement with the United States, in force from 2026.
Read the analysisSend me the document on WhatsApp or by e-mail. An initial analysis shows whether the decision can be appealed and which Irish documents are needed.