Introduction
In 2025, tax regulations for legal entities in Romania bring significant changes in terms of taxes, contributions, and reporting obligations. Companies need to stay informed about the new provisions to avoid penalties and take advantage of potential tax benefits.
In this article, we analyze the main tax changes in 2025 and their impact on the business environment.
Table of Contents
1. Tax on dividends earned by legal entities
Increase in the tax rate to 10% (previous tax rate was 8%)
The tax on dividends is determined by applying a 10% tax rate on the gross dividend paid to a Romanian legal entity.
Effective date: The new 10% rate applies to dividend income distributed after January 1, 2025.
2. Tax on microenterprise income
2.1 Reduction of the Revenue Threshold for Eligibility in This Tax System
A microenterprise is considered a Romanian legal entity that, as of December 31 of the previous fiscal year, has generated revenues not exceeding the RON equivalent of €250,000, and starting from January 1, 2026, this threshold will be reduced to €100,000.
Effective date: January 1, 2025
2.2 Elimination of the Revenue Share Condition for Consultancy and/or Management Services
The requirement that the share of consultancy and/or management revenue in total income must be less than 20% to qualify for the microenterprise income tax is removed.
Effective date: January 1, 2025
2.3 Application of the 3% Tax Rate for Certain CAEN Codes
Starting from January 1, 2025, the 3% tax rate will apply to both primary and secondary activities that fall under the following CAEN codes:
6210 – Custom software development (client-oriented software)
6290 – Other IT service activities
5611 – Restaurants
5612 – Mobile food service activities
5622 – Other catering services n.e.c.
Effective date: January 1, 2025
2.4 Transition to Profit Tax When Revenue Exceeds the Threshold
If a microenterprise exceeds the €250,000 revenue threshold during a fiscal year (or €100,000 starting January 1, 2026), it will be required to pay corporate income tax starting from the quarter in which the limit was exceeded. Once this threshold is crossed, the company cannot opt for microenterprise taxation in the following period.
Effective date: January 1, 2025
2.5 Revenue Limit Verification for Fiscal Year 2025
For the 2025 fiscal year, the revenue threshold of €250,000 (or €100,000 starting from January 1, 2026) will be verified based on the revenues earned by the Romanian legal entity as of December 31, 2024, and December 31, 2025, respectively.
The condition related to the share of consultancy and/or management revenue in total revenue, which was in place as of December 31, 2024, will not be considered when calculating the €250,000 limit.
Effective date: January 1, 2025
3. Income tax
3.1 The income tax exemption for employees in the IT, construction, agricultural sector, and food industry is eliminated.
Effective date: Starting with income related to January 2025
3.2 The tax rate on dividend income earned by individuals increases. Income in the form of dividends, including gains obtained from holding participation titles defined by the relevant legislation in collective investment undertakings, is taxed at a rate of 10% on the total amount, with the tax being final.
Previous tax rate: 8%
Effective date: The new 10% rate applies to dividend income distributed after January 1, 2025
4. Contribution to state social insurance (public pension system)
For employees in the IT, construction, agricultural, and food sectors, the provisions regarding the reduction of the social insurance contribution rate by the percentage points corresponding to the contribution rate to the privately managed pension fund are repealed.
Effective date: Starting with income related to January 2025
5. Tax on income earned by non-residents
The tax rate increases from 8% to 10% for income earned by non-residents in the form of dividends.
Effective date: The new 10% rate applies to dividend income distributed after January 1, 2025
6. Tax on constructions
The tax on constructions is calculated by applying a 1% rate to the value of constructions owned by taxpayers as of December 31 of the previous year, minus the value of buildings for which a property tax is already due.
This provision also applies to the value of buildings located in industrial, scientific, and technological parks that, according to the law, do not benefit from an exemption from property tax.
For constructions that are part of the public/private domain of the state or administrative-territorial units, the tax is owed by taxpayers who administer, lease, use free of charge, or hold them under concession.
The construction tax must be paid in two equal installments by June 30 and October 31, respectively.
Effective date: January 1, 2025
