If you have moved abroad but keep ties to Romania, the decisive question is not where you live now, but whether you have ceased — in the sense of the law — to be a Romanian tax resident. Physical departure alone changes nothing; what changes things are the legal criteria and the documents filed on time. On 24 June 2026, ANAF (the Romanian tax authority) announced a new wave of notices to persons with foreign income for 2025.
It is the status that answers a single question: which state has the right to tax your worldwide income. A Romanian tax resident owes tax in Romania on income from any source, at home and abroad; a non-resident owes tax only on Romanian-source income (Article 59 of the Romanian Fiscal Code, the main direct-tax statute).
A Romanian tax resident is taxable here on the dividends from the Cyprus company, the gains from the US broker, the rent from Spain — subject to the exceptions the law sets out expressly (for instance, salaries paid by a foreign employer for work physically performed abroad). You do not pass from one status to the other simply by buying a plane ticket, but through an administrative procedure supported by evidence.
Under Article 7 point 28 of the Fiscal Code, you are a Romanian tax resident if you meet at least one of the following conditions. The criteria are alternatives: a single one is enough.
As long as your domicile (permanent legal home) remains here, Romanian law continues to treat you as resident — regardless of how many months you spend outside the country.
The state with which your personal and economic relations are closest. This is the criterion that catches most of those who have left.
In total, during any period of 12 consecutive months ending in the calendar year in question — not necessarily the calendar year itself.
Romanian citizens working abroad in that capacity remain Romanian tax residents by operation of law.
The centre of vital interests is the state with which your personal and economic relations are closer. ANAF looks at the whole picture: where your spouse and children live, where you have a permanent home available (owned or rented), where your main accounts and investments are, where you hold businesses or shareholdings, from where you manage your wealth, where you hold insurance, a doctor, and steady social ties.
Someone who works ten months a year abroad, but whose family, home and business remain in Romania, has — on the tax authority's typical reading — their centre of vital interests in Romania. Days spent outside the country do not, on their own, offset that anchor. This is why physically moving to another state does not automatically remove you from the residence net: the matter is settled only through the change-of-residence procedure and, in case of conflict, through the applicable double taxation treaty.
The procedure is governed by Order of the Minister of Public Finance no. 1099/2016, still in force in 2026. Resident individuals leaving the country for stays abroad exceeding, in total, 183 days over any period of 12 consecutive months must file the form titled "Questionnaire for establishing the tax residence of an individual on departure from Romania" (Z017), 30 days before departure, with the competent tax office (Article 59 read together with Article 230(7) of the Fiscal Code). The mirror image applies on the way in: anyone arriving in Romania and exceeding 183 days files the arrival questionnaire (Z015) within 30 days of meeting the threshold.
The questionnaire is filed 30 days before departure, not after you have settled in the new state.
Employment or service contract in the destination state, proof of housing (purchase or lease), tax registration there, relocation of the family where applicable.
Your answers about the home in Romania, the family, the accounts and the businesses left behind are precisely the elements ANAF will weigh under the centre-of-vital-interests test.
Including, if you already hold it, the tax residence certificate issued by the authority of the destination state.
Electronically, through the SPV (the "Virtual Private Space", ANAF's online filing portal), or at the registry.
Within 30 days of filing, the tax office tells you — based on the applicable treaty and the Fiscal Code — whether you keep full tax liability in Romania or will be taxed only on Romanian-source income.
And obtain, for each relevant year, the residence certificate of the new state — that is the evidence that counts in any later audit.
IMPORTANT. Failure to file the questionnaire is punished as a minor offence, with a token fine (RON 50–100, according to ANAF's own materials). The real consequence, however, is different: you remain registered as a Romanian tax resident, taxable on worldwide income, and foreign income that ANAF learns of through the automatic exchange of information can be assessed on the authority's own initiative, with interest and penalties. And if you have moved to a state with which Romania has no double taxation treaty, Article 59(3) of the Fiscal Code keeps you taxable in Romania on worldwide income for the year of departure and for a further three years afterwards. By contrast, someone who proves a change of residence to a treaty state owes worldwide-income tax only up to the date of departure.
A tax residence certificate is the official document by which a state confirms that you are its tax resident. It has two key uses. First, the certificate of the foreign state is the central proof of a change of residence: it is attached to the departure questionnaire and supports the end of full tax liability in Romania.
Second, for income that continues to flow from Romania after departure (dividends, interest, rent), presenting the certificate to the Romanian payer is what allows the reduced treaty rates to apply (Article 230 of the Fiscal Code); a certificate presented during the year of payment remains valid for the first 60 calendar days of the following year, provided the residence conditions have not changed. Conversely, someone who stays a Romanian resident and earns income abroad needs the Romanian certificate, issued by ANAF on request (including through the SPV portal), to invoke the treaty in the source state.
It happens frequently that two states consider you resident at the same time — Romania on the domicile or centre-of-vital-interests criterion, the host state on the presence criterion. The conflict is resolved by Article 4 of the applicable treaty, which sets out a cascade of criteria, checked in strict order.
You are resident of the state in which you have a permanent home available to you. If you have one in both states, the next criterion applies.
The state with which your personal and economic relations are closer. If this cannot be determined, the analysis moves on.
The state in which you habitually live. If you live habitually in both or in neither, the analysis moves on.
A subsidiary criterion, applicable only if the preceding ones have not resolved the conflict.
As a last resort, the mutual agreement procedure between the two tax administrations.
The cascade explains why keeping a permanently available home in Romania, and the family here, weighs so heavily: even if the host state issues you a residence certificate, on the permanent-home and centre-of-vital-interests tests Romania may still "win" — with the consequence that worldwide income is taxed here.
This is probably the most expensive confusion in the international taxation of individuals. Incorporating a company in a low-tax jurisdiction changes nothing about your own tax residence: the company and the shareholder are separate tax subjects. If the centre of your life — family, home, businesses actually run — remains in Romania, you remain a Romanian tax resident, and the dividends or other sums extracted from the foreign company are taxable in Romania.
Moreover, if the "Dubai" company is in fact managed from Romania, the company itself may be classified as a Romanian tax resident on the place-of-effective-management criterion (Article 7 point 37 of the Fiscal Code), with its profits taxed here. Romania does, in fact, have a double taxation treaty with the United Arab Emirates (signed in 2015, in force from 2017) — which means that dual residence is settled on the criteria above, not by the mere holding of a free-zone visa or licence.
The husband works in Germany or Belgium 10–11 months a year; the wife and children stay in the family home. The centre of vital interests usually remains in Romania — so does residence, with the obligation to declare worldwide income. Not filing the questionnaire changes nothing for the better: it only leaves the situation undocumented.
Someone who works remotely from several countries, without settling for tax anywhere, usually stays "anchored" to Romania: domicile persists, and without a residence certificate issued by another treaty state there is no proof required by Article 59. A passport full of stamps is not proof; a lease, a tax registration and a residence certificate are. The details, in the analysis on digital nomads and taxes.
A Romanian pension remains Romanian-source income, but its treatment — taxed here, in the state of residence, or in both with a credit — depends on the applicable treaty. Retirees, too, must file the departure questionnaire if their stay exceeds 183 days.
On return, if presence exceeds 183 days, the arrival questionnaire is filed. Savings brought back from abroad are not taxed as income on mere repatriation, but they must have a documentable source: in a personal tax-position review, sums without a justified origin can be treated as unexplained income.
Through CRS/DAC2 (the OECD Common Reporting Standard and its EU equivalent), ANAF receives each year balances, interest, dividends and gross proceeds from accounts held by Romanian residents at financial institutions in more than 100 jurisdictions — and the notice campaign announced on 24 June 2026 for 2025 income is precisely the product of this data. Through DAC1, information arrives on salaries, pensions and income from real estate located in other EU states. From 2026, Emergency Ordinance no. 71/2025 (transposing DAC8) extends automatic reporting to crypto-assets, with the first reporting in 2027.
Domestically, ANAF Order no. 768/2026 has extended the competence to conduct personal tax-position reviews to the Antifraud structures, and income whose source cannot be identified is taxed at 70% (a rate in force since July 2024). During the review, the tax office can also request the statement of assets and income. For anyone registered as a Romanian resident without having declared anything, each of these data flows is a starting point for a review.
Yes. The questionnaire can be filed late, together with the evidence of the change of residence (foreign residence certificate, employment contract, housing), and ANAF will issue its notice on your status. It is clearly preferable to clarify the situation on your own initiative than to have it opened by a notice based on CRS data. Past periods are assessed individually, on the evidence.
No. The 183-day rule is only one of the criteria. Domicile and the centre of vital interests in Romania keep you resident even with minimal physical presence here, and in case of dual residence the treaty criteria decide: permanent home, centre of vital interests, habitual abode, nationality.
It remains taxable in Romania, as the source state: rent, dividends, interest and pensions from here are taxed under the Fiscal Code and the treaty with your state of residence. To obtain the reduced treaty rates you must present the tax residence certificate to the Romanian payer at the time of payment.
Not absolutely. The notice reflects the situation as declared at that time. If the real circumstances change — the family returns to Romania, you again spend most of your time here, you run your businesses from here — the residence criteria are reassessed on the merits, and ANAF can revisit your status for the years in which the Romanian anchors again became dominant.
Informational material, updated on 18 July 2026. It does not constitute legal or tax advice; individual situations must be assessed case by case.
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.