Romania: Repeal of tax on “nonresident affiliates”; transition period for individuals using e-invoicing system
Amendments to the fiscal procedure code
Ordinance no. 6/2026, published on January 30, 2026, includes the repeal of Article 25¹ of the Fiscal Code, which previously governed taxpayers recording expenses involving affiliated entities not established or managed in Romania. This repeal aims to eliminate risks of double taxation, discriminatory treatment, or divergent interpretations, aligning Romania's tax legislation with OECD standards.
Additionally, the ordinance provides provisions concerning the RO e-Invoice System for individuals. Individuals conducting economic activities identified by their personal identification number (CNP), including those earning income from copyright, are granted a transitional period until June 1, 2026, during which the use of the system is not mandatory. The registration procedure will be updated by the National Agency for Fiscal Administration (ANAF) within 30 days of the ordinance's entry into force.
Read a February 2026 report prepared by the KPMG member firm in Romania