You work in construction under the CIS, in warehouses, in care or on delivery platforms, with a National Insurance number and with tax paid to HMRC. If ANAF, Romania’s national tax administration, still considers you a Romanian tax resident, your British income can end up in a tax assessment decision (decizie de impunere) in Romania, and for those who work as self-employed the risk is greater than for employees.
Salary received for work actually performed in the United Kingdom and paid by a British employer is not taxable in Romania and is not declared here (Article 76(4)(o) of the Tax Code).
The exemption, however, covers only income from dependent activities, that is, salary. Income earned as self-employed, including through the Construction Industry Scheme or on delivery and transport platforms, is income from independent activities. For a Romanian tax resident, this income is declared in Romania, and the tax paid in the United Kingdom is deducted by way of a foreign tax credit, under the terms of the treaty.
This is where many of ANAF’s decisions for Romanians in the United Kingdom come from: income treated as independent, with no credit for the British tax where that tax has not been proven, to which contributions calculated in Romania may be added. The first question is, every time, residence: if it has moved to the United Kingdom, the obligation to declare in Romania disappears.
It is a common misconception that, after Brexit, the Romanian tax authorities no longer find out what a Romanian earns in the United Kingdom. The United Kingdom applies the OECD Common Reporting Standard (CRS): British banks report the accounts of non-residents, with balances, interest, dividends and sale proceeds, and the data reaches the tax administrations of the states of residence automatically. Through the CRS, data on tens of millions of accounts circulates across more than 100 jurisdictions; in 2022, on 111 million.
The new treaty between Romania and the United Kingdom also contains exchange-of-information clauses, applicable from its entry into force in December 2025. And the accounts in Romania to which you send money, the transfers and the purchases of assets are visible to ANAF in any case.
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 British income, a notice is issued.
The British tax year begins on 6 April and ends on 5 April, while the Romanian one follows the calendar year. The documents must be kept for each British tax year, so that the income can be apportioned correctly.
The annual document from your employer, received by 31 May, showing the salary and the tax paid in the British tax year ended on 5 April.
Payslips and the document received when a job ends. They show the employer and the period worked.
The tax calculation from the Self Assessment return, for those who work as self-employed. It is the evidence of British tax on independent income.
The monthly statements received from the contractor under the Construction Industry Scheme, showing the amounts deducted at source.
The certificate of tax residence issued by HMRC on request. It is the document that matters most when ANAF disputes your residence.
The record of British contributions. It answers claims for CAS, the state pension contribution, or CASS, the health insurance contribution, in Romania for the same years.
The United Kingdom determines tax residence through the statutory residence test, based on the days spent there and your ties with the country: home, work, family. Status obtained through the EU Settlement Scheme is an immigration status, not a tax status. 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 decides. The new treaty between Romania and the United Kingdom, ratified by Legea nr. 169/2025, applies in Romania from 1 January 2026 and in the United Kingdom, for income tax, from 6 April 2026. For earlier years the 1975 treaty remains applicable, so an ANAF decision for 2021-2025 is analysed under the old text. See also dual residence.
For situations that began after 1 January 2021, the Protocol on Social Security Coordination, annexed to the agreement between the European Union and the United Kingdom, applies. The basic rule remains that of the state in which the work is performed: National Insurance contributions paid in the United Kingdom cover the same risks as CAS and CASS.
For those who work as self-employed, the question of contributions is more delicate, because ANAF may calculate CASS on independent income declared in Romania. The National Insurance record and, where necessary, the coordination documents issued by the authorities are the evidence that counts. Details on the A1 document and the United Kingdom.
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 paid to HMRC and the National Insurance contributions. 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 the United Kingdom may be treated as unjustified income, taxable at 70%, if their source is not proven.
I work with Romanians in the United Kingdom without their having to travel to Romania. The legal assistance agreement is signed remotely, and 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 British documents yourself from your HMRC account or receive them from your employer or contractor; I will tell you exactly what is needed for each year.
I carry out the analysis as a lawyer, tax adviser and forensic tax expert, including the apportionment of income between the British tax year and the Romanian one, which is where mistakes are most often made in calculating the foreign tax credit.
No. Salary paid by a British employer for work in the United Kingdom is not declared and is not taxed in Romania (Article 76(4)(o) of the Tax Code). Keep your P60 for each British tax year.
If you are a Romanian tax resident, yes: independent income from the United Kingdom is declared in Romania, with a credit for the tax paid to HMRC, under the terms of the treaty. If your residence has moved to the United Kingdom, the obligation disappears. That is why the first question is residence.
Not automatically. Immigration status is not tax residence. What counts are the criteria in the Romanian Tax Code, the British residence test and, if both states consider you resident, the treaty between Romania and the United Kingdom.
The new treaty, ratified by Legea nr. 169/2025, applies in Romania from 1 January 2026 and in the United Kingdom, for income tax, from 6 April 2026. For earlier years the 1975 treaty applies, so an ANAF decision for the years 2021-2025 is analysed under the old text.
Yes. The engagement is signed remotely, I represent you under a lawyer’s power of attorney (împuternicire avocațială), and our discussions take place 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 an Irish employer for work performed in Ireland is not taxed in Romania, but ANAF can issue decisions covering the last 5 years. Employment Detail Summary, PRSI, the 183-day test 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 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 notice or the decision on WhatsApp or by e-mail. I will tell you what can be challenged and which British documents are needed.