On Thursday, August 14, 2025, the Ministry of Finance published a draft law proposing a series of changes in the tax area in order to bring the level of tax revenues in Romania in line with the average of European Union states, as a percentage of Gross Domestic Product, according to the introductory report. Below is a summary of the second package of tax measures in Romania:
The Ministry’s proposals include, among others, a requirement for LLCs to have a registered capital of 8,000 lei (recall that previously the minimum was 200 lei).
“Limited liability companies registered in the commercial register will increase their share capital at the first mention of an amendment in the articles of incorporation, but no later than 2 years after the effective date of this law,” the bill reads.
The amount of 8,000 lei comes from updating the capital stock level of 200 lei with the consumer price index for the period from January 1990 to December 2024.
In addition, the draft law regulates the following: – legal entities are required to hold an account with a credit institution in Romania for the duration of their activity; – newly established legal entities are required to open an account with a credit institution within 30 business days from the date of incorporation.
The new provisions take effect on January 1, 2026.
Regarding corporate income tax, the bill proposes to repeal the minimum turnover tax (IMCA) for determining corporate income tax due, starting from fiscal year 2026/amended fiscal year beginning in 2026. In addition, the additional tax for legal entities conducting business in the oil and natural gas sectors – ICAS, shall apply until December 31, 2025/last day of the amended fiscal year ending in 2026.
The Ministry is also considering raising the ceiling up to which the health insurance contribution for self-employment income is due from 60 minimum gross salaries per guaranteed country to 90 minimum gross salaries per country for income received on or after January 1, 2026, as well as applying a fixed rate of 30 percent on gross income from accommodation services.
The draft also modifies the special regime for taxpayers who record costs with affiliated entities.
“Taking into account the good practices applicable in other countries (Poland, Hungary, the United States, etc.), it is proposed that for taxpayers who exceed a certain percentage of expenses related to intellectual property rights, management fees, consulting fees, interest expenses, with affiliated entities, compared to the total expenses of the same nature, such expenses incurred with affiliated entities shall be considered non-deductible in the calculation of tax result,” the explanatory report states. The threshold has been set at 3 percent.”
Thus, Romania’s new fiscal course is marked by the recovery of taxes due and already assessed or declared in a more rapid and stringent manner, in the greater empowerment of the taxpayer who is obliged to open or maintain a bank account in Romania (too bad that credit institutions in Romania are not particularly lenient on the subject of bureaucracy in dealing with their customers); in the same direction are the regulations that raise the minimum share capital (to guarantee corporate debts) and capitalization of private economic operators.
source MdF Romania, ZF
