I.    Changes regarding the deadlines for declaration and payment for corporate income tax
II.   Relaxation of the conditions for classification as a micro-enterprise
III.  Granting a 3% tax bonus
IV.  Tax incentives for corporate income and micro-enterprise income taxpayers
V.   Income tax incentives
VI. Changes regarding the application of the VAT collection system

I.    Changes regarding the deadlines for declaration and payment for corporate income tax 

The annual deadline of June 25, for declaring and paying corporate income tax, provisionally used in the last 5 years, becomes definitive. This deadline will also apply to Romanian legal entities with special taxation rules (e.g. religious cults, educational establishments, non-profit organizations) and to those who obtain majority income from agriculture.  

As for taxpayers with a modified fiscal year, they have as an annual deadline the 25th of the sixth month, inclusive, from the end of the modified fiscal year.

For taxpayers who apply the annual corporate income tax declaration and payment system, with quarterly advance payments, the advance payment for the first quarter of each fiscal year/modified fiscal year is calculated by applying the tax rate on the accounting profit of the period for which the advance payment is made and this is declared and paid by the 25th of the month following the first quarter.

The provisions apply starting with the annual corporate income tax return for the year 2026 / the modified fiscal year starting in 2026.

II.    Relaxation of the conditions for classification as a micro-enterprise 

The main changes regarding the application of the micro-enterprise income tax system are:

• When determining the threshold for the classification as a payer of micro-enterprise income tax, the income that constitutes the turnover defined according to the applicable accounting regulations plus the income from the transfer of fixed assets/land under certain conditions is taken into account.  
• The condition that the legal person should not have previously been a payer of micro-enterprise income tax is eliminated.
• For newly established legal entities, the deadline for fulfilling the condition regarding the existence of an employee is extended from 30 days to 90 days.
• The condition regarding the possession of an employee is also considered fulfilled if the employee is on leave for temporary incapacity for work, according to the law, provided that the cumulative period of leave for temporary incapacity for work, for the entire fiscal year, does not exceed 30 days.
• The income representing the 3% tax bonus granted by the tax authorities is deducted from the tax base.

Taxpayers who, in the period between January 1, 2026 and February 25, 2026, notified the tax authorities of the application of the microenterprise income tax regime or, as the case may be, of their exit from the microenterprise income tax regime, shall submit, where applicable, a new statement of amendments in order to determine their eligibility for the application of the microenterprise income tax.

The provisions apply for the verification of the conditions, including for the classification as micro-enterprises in the 2026 fiscal year.

III.    Granting a 3% tax bonus 

Corporate income taxpayers, as well as micro-enterprise income taxpayers, may benefit from a 3% bonus applied to the annual corporate income tax and to the micro-enterprise income tax related to the 2025 fiscal year / to the amended fiscal year beginning in 2025, as applicable. In the case of a tax group, the bonus is applied to the annual corporate income tax declared by the responsible legal entity.  

The 3% bonus is granted provided that all declarative and payment obligations related to corporate income tax and/or micro-enterprise income tax are duly fulfilled.

Clarifications are also provided for the following situations: taxpayers who redirect amounts from the annual corporate income tax; micro-enterprise income taxpayers; micro-enterprises that become corporate income taxpayers in 2025; and taxpayers who submit corrective returns after the bonus has been granted.

As a general rule, the 3% bonus is granted ex officio and is not refundable; instead, it is used to offset the taxpayer’s fiscal obligations.

Individual taxpayers benefit from a 3% bonus applied to the income tax due for income earned in 2025, for which there is an obligation to submit the Annual Tax Return, provided that both the filing and the payment are made by 15 April 2026 inclusive.

In this case, the bonus is calculated by the taxpayer and reported separately in the Annual Tax Return, subject to subsequent verification by the tax authorities. The income tax payable is determined by reducing it by the amount of the 3% bonus. This implies that there are no outstanding tax liabilities for previous years.

Additional clarifications are provided for taxpayers who submitted the Annual Tax Return and/or paid the tax prior to the entry into force of this Ordinance.

IV.    Tax incentives for corporate income and micro-enterprise income taxpayers 

A. Introduction of a tax credit system for research and development activities

Taxpayers can opt for the application of a tax credit, as an alternative to additional deductions when calculating the tax result. The tax credit is calculated by applying the percentage of 10% to the value of the eligible expenses for research and development activities, recorded by the taxpayer during the fiscal period for which the calculation of the corporate income tax / minimum turnover tax is carried out.  

If the tax credit is partially deducted from the corporate income tax, the difference is offset or refunded within 4 years. In the calculation of the tax result, this difference is considered non-taxable income.

Clarifications are also made regarding the application of the tax credit to taxpayers who owe minimum turnover tax, as well as to those who are part of a tax group.

The provisions apply starting with the fiscal year 2026, respectively with the modified fiscal year starting in 2026.

B. Clarifications regarding the reserves constituted as a result of the application of the tax exemption of the reinvested profit

New rules are introduced regarding the use of tax reserves constituted as a result of applying the reinvested profit tax incentive.

Taxpayers who register tax reserves according to the provisions regarding the tax exemption for the reinvested profit, starting with the fiscal year 2026/amended fiscal year starting in 2026, can use them after a period of 5 years to apply a favorable tax treatment, namely:

• if the reserves are used for distribution, 50% of their value is taxed as items similar to income in the fiscal period in which they are used;
• if the reserves are used to increase share capital and/or to cover losses, they do not represent items similar to income and are not subject to tax.

The provisions also apply to the reserves existing in the accounting records on December 31, 2025, respectively on the last day of the amended fiscal year ending in 2026. The amounts representing the use of reserves are taxed in the order in which they are registered.

If such tax reserves are maintained until liquidation, they are not taken into account in determining the fiscal result upon liquidation.

The provisions apply starting with the fiscal year 2026, respectively with the modified fiscal year starting in 2026.

C. Changes in depreciable fixed assets

The tax value for classifying an asset as depreciable fixed asset is increased, from RON 2,500 to RON 5,000. For fixed assets with an initial tax value between RON 2,500 and RON 5,000, existing in the taxpayers' patrimony on December 31, 2025, respectively on the last day of the amended fiscal year ending in 2026, the remaining undepreciated tax value is recovered during the remaining normal period of use. 

A new depreciation method is also introduced – super-accelerated depreciation – which allows the depreciation of up to 65% of the tax value of the asset in the first year of use. The method applies to new assets in subgroups 2.1 "Technological equipment" and 2.4 "Animals and plantations", purchased/produced and put into operation in 2026 / in the amended fiscal year starting in 2026.

Specific rules are provided for taxpayers applying a modified tax year.

The provisions apply starting with the fiscal year 2026, respectively with the modified fiscal year starting in 2026.

V.    Income tax incentives 

The category of deductible expenses is extended for taxpayers who determine the annual net income from independent activities in the real system. Within the limit of 400 euros per year/person, the following are deductible:

• contributions to occupational pension funds;
• contributions to pan-European personal pension products (PEPPs);
• amounts paid for the acquisition of shares, bonds and/or equity securities issued by undertakings for collective investment in marketable securities (ETFs), through the entities referred to in art. 96^1 para. (1) Fiscal Code, not including the costs related to the transaction.

The deduction is allowed under certain conditions and on the basis of the supporting documents expressly provided by law.

Also, the contributions to an occupational pension fund borne by the employer for its own employees represent non-taxable income from the perspective of income tax from salaries, within the limit of 400 euros per year/person and the monthly threshold of maximum 33% of the basic salary.

The provisions enter into force from March 1, 2026.

VI.    Changes regarding the application of the VAT collection system 

The threshold for the application of the VAT collection system is increased, in two stages, as follows:

• RON 5,000,000, between March 1 and December 31, 2026;
• RON 5,500,000, starting with January 1, 2027.

Transitional measures are also introduced allowing taxpayers who exceed the previous threshold of RON 4,500,000 during January or February 2026, but do not exceed the new threshold of RON 5,000,000, to continue applying the VAT collection system.

The fiscal measures presented were introduced by the Emergency Ordinance no. 8/2026 on the establishment of measures for economic recovery, the increase of productive investments and competitiveness, as well as for the amendment and completion of some normative acts in the fiscal-budgetary field, published in the Official Gazette no. 147 of February 25, 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.

Crowe România