The contract is with a company in Cyprus, the ship flies the Maltese flag, the money comes from an account in Singapore, and you live in Constanța between voyages. Four states, two separate questions, and a single person who has to answer for both. The rules exist, but they are not the same for contributions and for tax, and for tax only one thing matters: who pays.
For social contributions, the rule starts from the ship's flag: in the European Union, activity on board a ship flying the flag of a Member State is treated as carried out in that state, with an exception for someone remunerated by an undertaking from their own state of residence. For income tax, the rule starts from who pays the salary: income paid by a non-resident employer for activity on board a ship in international traffic is not taxed in Romania and is not declared.
The two analyses are independent. You can end up with contributions in one state and tax nowhere, or contributions in Romania and tax under a treaty. No combination is assumed; each is verified.
A seafarer's situation is analysed on three levels, in this order: tax residence, the applicable social security legislation, and income tax.
Tax residence is determined under the Tax Code and, in the event of a conflict, under the treaty's criteria. It answers the question of which state has the right to tax the person's worldwide income. A seafarer who keeps their domicile and family in Romania generally remains a Romanian tax resident, no matter how many days they spend at sea.
Social security follows, within the European area, Regulation (EC) No 883/2004 and its implementing Regulation No 987/2009, and outside it, bilateral agreements or, in their absence, national legislation. The document attesting the applicable legislation is the A1 portable document, for which CNPP (the National Pension House) has published a dedicated form for seafaring personnel.
Income tax follows the Tax Code, which treats income paid by non-resident employers separately, and, when the employer is resident in Romania, the double taxation treaty with the state where the activity is carried out, which usually contains a special provision for personnel on board ships in international traffic.
Article 11(4) of Regulation (EC) No 883/2004 provides that an employed or self-employed activity normally carried out on board a vessel at sea flying the flag of a Member State is treated as an activity carried out in that Member State.
The consequence is that a seafarer on a ship flying the Maltese, Greek or Cypriot flag is, in principle, subject to the social security legislation of the flag state, even if they have never set foot on its territory.
The same paragraph provides, however, an exception with considerable practical effect: an employee who carries out their activity on board a ship flying the flag of a Member State and who is remunerated by an undertaking or a person with its seat or domicile in another Member State is subject to the legislation of that latter state, if they reside there. The undertaking paying the remuneration is regarded as the employer for the purposes of that legislation.
Translated into concrete situations: a seafarer resident in Romania, remunerated by a company in Romania for work on a ship flying the Maltese flag, stays in the Romanian system. A seafarer resident in Romania, remunerated by a company in Malta for the same ship, enters the Maltese system. The difference is not made by the flag, but by who pays and where the person paid lives.
Outside the European area, for flags such as Liberia, Panama or the Marshall Islands, the regulation does not apply. Coordination depends on whether a bilateral social security agreement exists between Romania and the relevant state, and in its absence, the situation is analysed exclusively under the Tax Code, where the regime for income paid by non-resident employers generally requires the individual to declare and pay the contributions in Romania, subject to the exceptions provided by law.
For a Romanian resident, Article 76(4)(o) of the Tax Code provides that amounts received from employed activities carried out in a foreign state and paid by a non-resident employer are not taxable in Romania, regardless of the tax treatment applied in that state. The implementing rules, at Article 12(19), specify that the rule includes employed activities carried out on board ships and aircraft operated in international traffic, and that this income is not declared and is not subject to the foreign tax credit.
The rule settles, for the most common situation of a Romanian seafarer, the question of tax: a contract with a non-resident shipowner or crewing agency, a salary paid from abroad, activity on board a ship in international traffic. The income is not taxed in Romania, is not declared, and no tax credit is claimed for any tax paid elsewhere. The essential condition is that the payer be non-resident; the text requires this expressly.
The situation changes when the salary is paid by an employer resident in Romania or with a permanent establishment here, for example a Romanian crewing company that is, legally, the employer. Then, under Article 12(20) to (22) of the implementing rules, the income is taxable in Romania if presence in the foreign state does not exceed the period set out in the treaty with that state, and taxable in the foreign state if it exceeds it. Treaties additionally contain a special rule for personnel on board ships in international traffic, which in older versions of the model allocates the right to tax to the state where the place of effective management of the undertaking operating the ship is located. Each treaty is read in its own terms.
That is why the correct question is not where the ship sails, but who is, legally, the payer of the salary and where they are resident. The employment agreement, the contract with the crewing agency and the payment documents answer it. A seafarer paid by a non-resident entity has a simple answer; one paid through a Romanian company has a treaty to read.
In every scenario, the data reaches ANAF. Salaries paid into an account abroad are reported through the automatic exchange of information, and the tax authority can ask for the classification to be justified. The document that matters then is not the employment agreement, but proof of the regime applied: the residence certificate, the attestation of the applicable social security legislation and, where applicable, proof of tax paid in another state.
It is established whether you remain a Romanian tax resident: domicile, family, home, the centre of vital interests. Days spent at sea are not, by themselves, days spent in another state.
The ship's flag is identified and, separately, the undertaking that actually pays the remuneration, with its seat. The crewing agency can be an intermediary or an employer; the contract decides.
European flag: Article 11(4) of Regulation 883/2004, with the exception for a payer from the state of residence. Third-country flag: a bilateral agreement, if one exists, otherwise the Tax Code. The document attesting the applicable legislation is obtained through the CNPP form for seafarers.
It is established whether the entity paying the salary is non-resident or resident in Romania. This is the criterion under Article 76(4)(o) and decides whether the income is excluded from taxation or falls under the treaty regime.
Non-resident payer: the income falls under Article 76(4)(o) and Article 12(19) of the implementing rules, and is neither taxed nor declared. Resident payer: the treaty with the state where the activity is carried out is read, including the rule for seafaring personnel, and it is established where it is taxable.
Employment agreements, proof of payment, the attestation of the applicable social security legislation and, where applicable, the residence certificate and proof of tax paid in another state, are kept. These are the documents ANAF will ask for, not the ones the shipowner asks for.
If the income is taxable, the Declarația unică (Form 212), Romania's single annual return for income tax and social contributions owed by individuals, is filed on time. If not, proof of the classification is kept, for the moment the tax authority asks for it.
Contributions follow the flag state, which coincides with the shipowner's state. Tax depends on the treaty between Romania and that state and on the classification under Article 76(4)(o). The clearest of the situations.
The exception under Article 11(4): a seafarer resident in Romania stays in the Romanian system, and the payer in Romania is the employer for the purposes of Romanian legislation, with all the related declaration obligations.
The regulation does not apply through the flag. It is examined whether it applies through the undertaking's seat and the seafarer's residence, and tax follows the treaty with the shipowner's state. A situation that calls for a careful reading of the contract.
No European coordination. A bilateral agreement, if one exists; otherwise, only the Tax Code. The greatest risk of double exposure on contributions and of the tax classification being challenged, precisely because there is no text tying the situation to any particular state.
The exclusion under Article 76(4)(o) requires a non-resident employer. A salary paid through a Romanian crewing company does not fall under it and follows the treaty.
The two regimes are independent. The exclusion from tax says nothing about contributions, which follow the regulation, the bilateral agreement or the Tax Code, as the case may be.
The flag decides contributions, and only as a rule, subject to the exception for a payer from the state of residence. For tax, the flag is, most of the time, irrelevant.
Accounts abroad are reported automatically. The question is not whether the tax authority will find out, but whether you will be able to prove the classification when it asks.
Under Article 11(4) of Regulation (EC) No 883/2004, an activity normally carried out on board a ship flying the flag of a Member State is treated as carried out in that state. Contributions follow, as a rule, the legislation of the flag state, and CNPP has a dedicated form for attesting the situation.
Yes. The exception in the same Article 11(4) provides that an employee remunerated by an undertaking with its seat in another Member State is subject to the legislation of that state, if they reside there. A seafarer resident in Romania, paid by an undertaking in Romania, remains subject to Romanian social security legislation even if the ship flies another European flag.
It depends on who pays the salary. For a Romanian resident, Article 76(4)(o) of the Tax Code excludes from taxation income from employed activities carried out in a foreign state and paid by a non-resident employer, and the implementing rules, at Article 12(19), expressly include activities carried out on board ships operated in international traffic. This income is not taxed in Romania, is not declared and is not subject to the tax credit. If the salary is paid by an employer resident in Romania, the regime is determined under the treaty with the state where the activity is carried out.
Outside the European regulations and in the absence of a bilateral social security agreement, there is no coordination. Contributions and tax are analysed exclusively under the Tax Code and under the double taxation treaty with the shipowner's state, if one exists. This is the situation with the greatest risk of double exposure or, conversely, of a total lack of cover.
What matters is who is, legally, the payer of the remuneration and where its seat is, because the European regulation is concerned precisely with the undertaking that pays. The crewing agency can be a mere intermediary or an employer, and the contract establishes which of these applies.
If the income is taxable in Romania, yes. If it falls within the scope of Article 76(4)(o), the implementing rules provide that it is not declared. The correct classification should be established before the deadline, not after a notice from the tax authority, since data on accounts abroad reaches ANAF anyway through the automatic exchange of information.
Informative material, updated on 18 September 2026. It does not constitute legal or tax advice; individual situations must be assessed on their own facts.
If the situation involves income, accounts or residence in another country, the related analyses are grouped under the international tax analyses. For assistance on such matters, see international taxation.
An initial discussion establishes the two answers separately: in which state contributions are paid, and whether the salary from the ship is taxable in Romania, based on the contract, the flag and the applicable treaty.