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GloBE Country Guide: Romania

Summary

Status Enacted Law
LawOn December 29, 2023, Law No. 431/2023 to implement the EU Minimum Tax Directive was published in the Official Gazette.

On December 19, 2023, the Romanian Parliament approved the ‘Draft Law on ensuring a global minimum level of taxation for MNE Groups and Large National Groups’.
Effective DateAccounting periods beginning on or after December 31, 2023
IIRYes (2024)
UTPRYes (2025)
QDMTTYes (2024)
Filing DeadlinesStandard
Safe HarboursTransitional CbCR Safe Harbour, the Non-Material Constituent Entity provisions of the Simplified Calculations Safe Harbour and the Transitional UTPR Safe Harbour

Contents
  1. Legislation
  2. General
  3. Differences to Model Rules
  4. Qualifying Domestic Minimum Top-Up Tax
  5. Administration and Filing
  6. Penalties

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