What is tx situation in Romania, how is company taxed?
What CFC rules are you referring to?
The standard CIT rate is 16% for Romanian companies.
Micro-companies are subject to a mandatory revenue tax rate in lieu of the standard CIT.
The tax rates used for micro-company income tax are:
- 1% for micro-companies with one or more employees.
- 3% for micro-companies with no employees.
The current rules are about to change from
1 January 2023 accordingly:
A Romanian legal entity can opt for the application of micro-company revenue tax if it cumulatively meets the following conditions as at 31 December of the previous year:
o The revenues derived did not exceed the RON equivalent of
EUR 500,000 (modified condition - the threshold is currently EUR 1 mil);
o The share capital is owned by persons other than the state and administrative-territorial units - (unmodified condition);
o It is not under dissolution, followed by liquidation(unmodified condition);
o At least 80% of its total revenues are generated from other than consulting and management activities (newly introduced condition);
o Has at least one employee (newly introduced condition);
o Has associates/shareholders that hold more than 25% of the value/number of participation titles or voting rights in no more than three Romanian micro-companies (newly introduced condition).
The micro-company regime cannot be applied by Romanian legal entities conducting activities in: banking; insurance and reinsurance, of the capital market, including intermediation activities in those fields; gambling; exploration, development or exploitation of oil and natural gas deposits.
