Effective 1 March 2026, Romania implemented a new set of fiscal amendments through Government Emergency Ordinance No. 8/2026 (OUG 8/2026).
Unlike the broad tax increases introduced on 1 January 2026, the ordinance does not primarily raise tax rates, but instead, clarifies calculation mechanisms, reduces interpretational inconsistencies, tightens compliance and introduces targeted investment incentives.
1. Minimum Turnover Tax (IMCA)
Who is affected: Companies subject to the Minimum Turnover Tax (IMCA).
Until 1 March 2026
• The comparison between corporate income tax (16%) and IMCA created interpretational inconsistencies.
• Certain deductions reduced the effective IMCA base.
From 1 March 2026
• The comparative mechanism is formally clarified.
• Certain deductions are now limited when determining the IMCA base and the formula is more strictly defined.
Practical Impact
The reform increases predictability but reduces optimisation flexibility. Companies near minimum tax thresholds should reassess projected tax exposure for 2026.
2. VAT at Collection – Extended Applicability
Who is affected: Small and medium-sized enterprises meeting eligibility thresholds.
From 1 March 2026
More companies may apply the VAT-at-collection system, meaning VAT becomes payable only upon invoice collection rather than issuance.
Practical Impact
This measure improves liquidity, particularly for businesses with extended payment terms or in sectors with delayed receivables.
3. Capital Market Incentives
Who is affected: Companies listed or preparing to list on regulated markets.
Until 1 March 2026
Listing expenses were deductible under standard corporate income tax rules.
From 1 March 2026
A 50% additional tax deduction applies to eligible listing and market-maintenance expenses.
Practical Impact
The measure encourages capital market participation and enhances tax efficiency for companies seeking financing through regulated markets.
4. Fiscal Reserves – Clarified Tax Treatment
Who is affected: Companies creating and using fiscal reserves.
Until 1 March 2026
Reserve utilisation rules were less explicitly regulated, generating uncertainty regarding potential taxation.
From 1 March 2026
• Clear conditions apply if reserves are used within five years.
• Improper utilisation may trigger corporate income tax adjustments.
Practical Impact
Companies should review reserve strategies and internal accounting policies to mitigate unexpected tax exposure.
Key Takeaway for Businesses
Romania’s fiscal framework is becoming more technically structured and compliance-oriented.
Companies operating in Romania should reassess minimum turnover tax exposure, VAT strategy, reserve utilisation policies and capital market financing strategies to ensure tax efficiency under the revised framework.
Our team can assist companies in assessing the impact of OUG 8/2026 and reviewing tax structures to ensure compliance with Romania’s updated fiscal framework. For more information, contact us at [email protected]