Romania is represented 15% tax on profits of multinational companies, according to the law published on Friday in the Official Gazette. Basically, two taxes are introduced: “additional” and “statewide additional”. We remind you that we are talking about a well-known revolution in the field of taxation after the agreement concluded with the OECD. In this sense, the European directive (2022/2023) has practically been transposed.

This applies to organizations that are located in Romania and are members of a group of multinational companies or a large national group, a group that has an annual revenue of at least the equivalent of 750 million euros in lei.

The Ministry of Finance has 12 months to develop application rules.

The effective tax rate of a group of large multinational companies must be compared with the minimum tax rate of 15% to determine whether the group should pay additional tax by applying the IIR (Income Inclusion Rules) and UTPR (Under-Taxed Profits Rules).

Therefore, if the effective tax rate is lower than the minimum rate in a particular jurisdiction, the tax must be allocated among the entities in the MNC group that are liable to pay that tax in order to meet the 15% rate.

If the share is less than the minimum, the parent group must apply the income inclusion rules (IRR) to its low-tax entities to ensure that such group is liable to pay tax at the minimum effective tax rate of 15%.