Context

The article is addressed to taxpayers that are part of a group of companies that are obliged to apply the rules on the global minimum tax.

In August 2025, clarifications were introduced applicable to constituent entities that prepare individual financial statements according to Order of the Ministry of Public Finances no. 1.802/2014 (“OMFP no. 1.802/2014”) on the approval of Accounting Regulations, to calculate and present deferred tax in the explanatory notes, starting with the financial statements for the financial year 2025. Alternatively, entities may choose to apply International Financial Reporting Standards („IFRS”) as the basis for accounting. See the tax alert published on this topic here.

In this context, legislative provisions have been introduced on how to apply and present these requirements.

In Detail

I. Provisions applicable to constituent entities applying the accounting regulations (OMFP no. 1.802/2014):

• The determination of the amount of receivables and liabilities related to deferred tax is carried out in compliance with the provisions of IAS 12 "Corporate Income Tax";
• The deferred tax is presented only in the explanatory notes of the financial statements, without being recorded in the accounting;
• The amount of the deferred tax corresponding to the result of the financial year is presented separately from the deferred tax related to the deferred result;
• The deferred tax is established in relation to the book value of the balance sheet items and their tax base.

The provisions also apply to units without legal personality and permanent establishments belonging to legal entities established in the European Union, which are required to present the deferred tax in form code 30 "Informative data", with the distinct highlighting of the value corresponding to the result of the financial year from that corresponding to the result carried forward.

Applicability

• Calendar financial year: starting with the annual financial statements for the 2025 financial year.
• Financial year different from the calendar year: from the beginning of the first chosen financial year starting after January 1, 2025.

Entities that no longer fall under the scope of the Global Minimum Tax Law, are not required to apply these requirements.

Practical Aspects

The requirements imposed on constituent entities applying national accounting regulations do not apply to non-legal establishments and permanent establishments belonging to legal entities established outside the European Union.

II. Provisions applicable to constituent entities that opt to apply International Financial Reporting Standards (IFRS):

• Constituent entities may apply IFRS-compliant accounting regulations starting with the financial statements for the financial year 2025, if they consider that they have the capacity to implement;
• These entities will organize and conduct accounting according to IFRS rules starting with the financial year 2026.

During the application of Law no. 431/2023 on the global minimum tax, the constituent entities that use IFRS standards have the obligation to ensure continuity in the application of international financial reporting standards.

Entities that are no longer covered by the Global Minimum Tax Law can choose either to maintain the application of IFRS or to switch to national accounting regulations.

These provisions were introduced by Order 203/2026 published in the Official Gazette, Part I no. 196 of March 13, 2026.

Disclaimer

The information contained in this newsletter is intended to give you an overview of new legislation; the newsletter does not contain a comprehensive analysis of each topic. For further information on the topics covered please contact us. No responsibility is accepted for decisions or omissions following the use of the content of this newsletter. All Crowe newsletters are available at the address www.crowe.ro.

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