Romania Issues a Draft Pillar 2 Form for Nominating a Filing Entity

Article 48(10) of the Romanian Minimum Tax Law provides that if there are several constituent entities in Romania which are part of the same group, payment of the domestic minimum top-up tax (DMT) may be made, at the option of the constituent entity submitting the DMT return, by a single designated entity. The option must be exercised within 6 months of the last day of the reporting year.

On June 20, 2025, a draft order to nominate a single designated entity for DMT purposes (for both declaration and payment) was issued.

Details required in the form include:

 – Identification of the entity submitting the notification (including whether it is the UPE, a designated filing entity, designated local entity or a constituent entity). 

– The multinational enterprise group/large domestic group to which the taxpayer belongs (the name that is commonly used in the preparation of the consolidated financial statements).

– Information on entities in Romania that are the subject of the notification. The notifying entity provides the name, address and tax identification number of each entity as well as the local entity designated for the declaration and payment of the DMT.

The information is generally reported as of the last day of the reporting fiscal year.

 – Information regarding the designated local entity in Romania for declaring and paying the DMT, including whether the taxpayer submitting the notification is the same as the local entity designated in Romania for the payment of the DMT.

– Contact details of the entity submitting the declaration

– The start and end dates of the fiscal period for reporting including identifying if this is the first reporting year covered by the notification.