Tax Compliance in Romania
Profit tax and micro tax computed and filed inside the accounting contract, by CECCAR-registered accountants. Tax Compliance in Romania
corporate tax
By Mihai Dumitrescu, VAT and tax compliance lead · Reviewed by Ioana Marinescu, Accounting and reporting client lead · Updated October 2026
Every Fiscal Code rate on this page is read in ANAF's consolidation of Law 227/2015 to Law 170/2026; the other acts are named where they are used.
Romanian corporate tax, the impozit pe profit (profit tax), is 16% of taxable profit under art. 17 of the Fiscal Code. A micro-enterprise that meets the 2026 conditions, including revenue not above EUR 100,000, pays 1% of its revenue instead (art. 47(1)(c), 51(1)). Profit tax is paid quarterly (art. 41(1)), and dividends distributed from 1 January 2026 carry a further 16%.

Two regimes, two bases: profit tax reads the year's fiscal result, the micro-enterprise tax reads the company's revenue.
The Romanian corporate tax rate is 16% of taxable profit, set by art. 17 of the Fiscal Code, Law 227/2015 as amended. This guide reads ANAF's consolidated text, last updated by Law 170/2026, which is a consolidation and not a republication. The alternative is the impozit pe veniturile microîntreprinderilor (micro-enterprise tax): 1% of revenue, not of profit (art. 51(1), 53(1)). A company that pays it is outside profit tax altogether (art. 13(2)(h)).
The 16% itself did not move in 2026; what moved is around it. The micro rate became a single 1% from 1 January 2026 (OUG 89/2025), the micro ceiling fell to EUR 100,000, dividends went to 16%, and the minimum turnover tax and the construction tax entered their last year. The dated list is in the section on what changed. Computing the tax each quarter and filing the returns is what our tax compliance service does inside the accounting contract; this guide states the rules.
| Tax | Rate and base | Who | Article |
|---|---|---|---|
| Profit tax (impozit pe profit) | 16% of taxable profit | Romanian legal persons; foreign legal persons for a permanent establishment | art. 17, 13(1) Fiscal Code |
| Micro-enterprise tax | 1% of revenue, a single rate from 1 January 2026 | companies that meet the Title III conditions, revenue up to EUR 100,000 | art. 47(1)(c), 51(1), 53(1) |
| Minimum turnover tax (IMCA) | 0.5% within the statutory formula, fiscal year 2026 only | companies with previous-year turnover above EUR 50 million | art. 18^1(1), (16), (17) |
| Night clubs, casinos and similar | at least 5% of the revenue of those activities | operators of those activities | art. 18 |
| Dividend tax | 16% of the gross dividend, dividends distributed from 1 January 2026 | dividends to Romanian companies, individuals and non-residents | art. 43(2), 97(7), 224(4)(b) |
| Construction tax | 0.5% of the net value of constructions not subject to building tax, 2026 text | Romanian legal persons, except public, R&D and non-profit bodies | art. 496(1)(a), 498(1)(a) |
Romanian corporate taxes in 2026 at a glance. Sources: the Fiscal Code, ANAF consolidation to Law 170/2026; dividend start date from Law 141/2025.
Two kinds of company pay Romanian company tax under art. 13(1) of the Fiscal Code. The first is every Romanian legal person, such as an SRL or an SA (art. 13(1)(a)). The second is a foreign legal person that carries on business in Romania through one or more sedii permanente (permanent establishments): it pays on the business run through them (art. 13(1)(b)). A Romanian company that pays the micro-enterprise tax under Title III is outside profit tax while it does so (art. 13(2)(h)).
The fiscal year is the calendar year. A company formed or closed during the year is taxed for the part of the year in which it existed, and a modified fiscal year is possible (art. 16(1)-(2)). Whether a particular activity of a foreign company creates a permanent establishment depends on the facts of each case, and this guide does not answer it.
The micro-enterprise tax is optional (art. 48(1) Fiscal Code), and it taxes revenue, not profit: its base is revenue from any source, less the items the article lists (art. 53(1)). A company that meets every condition of art. 47(1), the main ones listed below, and notifies the option pays 1% of that revenue (art. 51(1)); a company that misses any condition pays 16% of its taxable profit. The law sets the conditions and their consequences; the regime in depth is in the micro-enterprise tax guide.
Which regime applies in 2026?
Start: a Romanian SRL. Every condition on the path must be met.
Every answer yes: micro-enterprise tax
1% of revenue, art. 51(1)
Any answer no: profit tax
16% of taxable profit, art. 17
New SRL 90 days from registration to meet the employee condition, art. 48(3)
Exit from 1% revenue passes EUR 100,000 in the year: profit tax from that quarter, art. 52(1)
Main conditions only; art. 47(1) lists more, all of which must be met.
For 2026 the ceiling is tested on revenue at 31 December 2025; for 2025 it was EUR 250,000, tested at 31 December 2024 (art. 54(3)). The list above gives the main conditions: art. 47(1) is cumulative and longer, and also requires, for example, annual financial statements filed on time. The 2026 list contains no condition on consultancy or management revenue.
Two of the conditions look past the company to its owners. Under art. 47(1^1), the revenue of every enterprise linked to the company is added to its own before the EUR 100,000 test is applied. Under art. 47(1)(h), the company must be the only legal person its shareholders holding more than 25% have set up to apply the micro regime. Neither test can be met by reading one company's own books alone.
The day-one rule changed with OUG 8/2026, in force from 25 February 2026, which gives a new company 90 days to meet the employee condition (art. 48(3) Fiscal Code).
The company is registered at ONRC, the trade register office. The 90-day term of art. 48(3) runs from that registration date.
If the company opts for the micro regime, meets the capital and one-micro conditions at registration, and has an employee, or an administrator paid at least the gross minimum wage, within 90 days, it pays micro tax from registration (art. 48(3)).
If not, the company owes profit tax from the quarter after the one in which the 90 days expire (art. 48(3)).
In the year after the one in which it was newly formed, a company paying profit tax applies the quarterly system, not the annual option (art. 41(6)(a)).
Each quarter, inside the accounting contract, we check three things for a micro-enterprise client: cumulative revenue against the EUR 100,000 ceiling, whether the employee or paid administrator is still in place, and whether a shareholder above 25% has set up another company on the micro regime. A change in any of them goes to the owner before the quarter's return is prepared.
Mihai Dumitrescu, VAT and tax compliance lead
Profit tax is charged on the rezultat fiscal (fiscal result). Under art. 19(1) of the Fiscal Code, it is the difference between revenue and expenses recorded under the accounting rules, minus non-taxable income and fiscal deductions, plus non-deductible expenses. The 16% of art. 17 applies to that result, not to the accounting profit. The table lists the main adjustments between the two figures.
| Item | Treatment | Article |
|---|---|---|
| Expenses incurred for the purpose of the economic activity | deductible | art. 25(1) |
| Protocol (entertainment) | deductible up to 2% of accounting profit plus the profit-tax and protocol expenses | art. 25(3)(a) |
| The company's own profit tax | not deductible | art. 25(4)(a) |
| Late-payment interest, penalties, fines and confiscations owed to Romanian or foreign authorities | not deductible | art. 25(4)(b) |
| Dividends received from a Romanian legal person | non-taxable income | art. 23(a) |
| Dividends from a subsidiary in another EU state, held at least 10% | non-taxable income | art. 24(1)(a) |
| Eligible R&D expenses | extra 50% deduction, plus accelerated depreciation of R&D equipment | art. 20(1)(a)-(b) |
| Profit reinvested in technological equipment, computers and software | exempt | art. 22(1) |
From accounting profit to taxable profit: the main adjustments. Source: the Fiscal Code, art. 19 to 25, ANAF consolidation to Law 170/2026.
The general rule of art. 25(1) is short: expenses incurred for the purpose of the economic activity are deductible. Some are deductible only within a limit, such as protocol, capped at 2% of accounting profit plus the profit-tax and protocol expenses (art. 25(3)(a)). Others are never deductible: the company's own profit tax (art. 25(4)(a)), and late-payment interest, penalties, fines and confiscations owed to Romanian or foreign authorities (art. 25(4)(b)).
Dividends a Romanian company receives from another Romanian legal person are non-taxable income (art. 23(a)), so they leave the fiscal result. Dividends from a subsidiary in another EU member state are non-taxable too where the Romanian company holds at least 10% of the subsidiary's capital, for at least one year (art. 24(1)(a)). The tax due when profit is paid out is a separate layer, covered below.
Law 239/2025 inserted art. 25^1 into the Fiscal Code, which from 1 January 2026 limited the deduction of IP, management and consultancy fees paid to non-resident affiliates to 1% of total expenses. OG 6/2026, published in Official Journal no. 77 of 30 January 2026, repealed the article (art. IV pt. 1). Under its art. V, those costs follow ordinary art. 25 deductibility from the first quarter of 2026, so no quarterly computation of 2026 applied the cap.
Four measures in the Fiscal Code and in OUG 8/2026 lower the tax a company pays.
Eligible R&D expenses carry an extra 50% deduction when the fiscal result is computed, and R&D equipment may be depreciated on an accelerated basis (art. 20(1)(a)-(b)).
Profit invested in technological equipment, production assets, computers and peripherals, software and the right to use software is exempt, computed quarterly or annually (art. 22(1), (5)).
Sponsorship is credited against profit tax, up to the lower of 0.75% of turnover and 20% of the profit tax due (art. 25(4)(i) pt. 1-2).
For fiscal year 2025, a company that filed every return and paid on time receives a 3% bonus on its annual profit tax or micro tax, granted ex officio by ANAF (OUG 8/2026 art. 7).
Yes, within a cap. A tax loss recorded from 2024 onwards is recovered from the taxable profits of the next 5 consecutive years, up to 70% of each year's taxable profit (art. 31(1) Fiscal Code). Losses recorded before 2024 keep their original window of 7 consecutive years, and the same 70% limit applies for the part of it that remains (art. 31(7)).
A micro period does not wipe out an earlier loss. A company that made a tax loss and then paid micro tax comes back under the art. 31(1) rule from the date it returns to profit tax (art. 31(5)). The loss is then set against the profits of the years that follow, within the same 70% limit.
Profit tax or micro tax, computed and filed by CECCAR-registered accountants.

Under the default quarterly system, profit tax is computed and paid by the 25th of the first month after quarters I to III: 25 April, 25 July and 25 October (art. 41(1) Fiscal Code). The payment return for state-budget taxes is form 100, which ANAF's forms page describes as completed by payers of taxes owed to the state budget. The micro-enterprise tax is computed and paid every quarter, by the 25th of the month after it (art. 56(1)).
| Obligation | Form | Period | Deadline | Article |
|---|---|---|---|---|
| Profit tax, quarterly system (the default) | form 100, the state-budget payment return | quarters I to III | the 25th of the first month after the quarter | art. 41(1) |
| Profit tax, annual system with advances (an option) | form 100 | each quarter | advances of one quarter of the previous year's tax, updated by the consumer price index | art. 41(2), (8) |
| Quarterly system compulsory | no separate form | the year after formation, a loss, inactivity or a micro year | the quarterly deadlines above | art. 41(6)(a)-(d) |
| Annual profit tax return | form 101 | the fiscal year | 25 June of the following year in art. 42(1); 25 March on ANAF's forms page (OPANAF 206/2025) | art. 42(1); ANAF forms page |
| Micro-enterprise tax | the quarterly micro-enterprise return | every quarter | the 25th of the month after the quarter | art. 56(1) |
| Micro option and exit | notice to ANAF | the year | 31 March | art. 55(2), (5) |
Payment and returns calendar for profit tax and micro tax. Sources: the Fiscal Code, art. 41, 42, 55 and 56; ANAF's forms page for forms 100 and 101.
Micro option or exit art. 55(2), (5)
notice to ANAF by 31 March
Profit tax, quarterly art. 41(1)
25 April, 25 July, 25 October
Micro-enterprise tax art. 56(1)
the 25th of the month after each quarter
Construction tax art. 499
declared by 25 May; paid by 30 June and 31 October
Form 101, annual return two official dates
25 March (ANAF forms page) or 25 June (art. 42(1))
Form 101: the statute and ANAF's forms page print different dates; both are shown with equal weight.
Instead of the quarterly system, a company may opt to compute, declare and pay profit tax annually, with advance payments made each quarter (art. 41(2)). Each advance is one quarter of the previous year's profit tax, updated by the consumer price index estimated for the budget (art. 41(8)). The option is closed in the year after a year in which the company was newly formed, made a loss, was inactive or paid micro tax: those companies apply the quarterly system (art. 41(6)(a)-(d)). The law offers both systems and does not rank them.
The annual profit tax return, the declarație anuală privind impozitul pe profit (form 101), carries two dates in two official texts. Art. 42(1) of the Fiscal Code sets 25 June of the following year. ANAF's forms page, citing OPANAF 206/2025, says form 101 is filed by 25 March of the following year. This guide does not choose between them. Before each filing, the accountant checks ANAF's fiscal calendar for the year in question.
Three charges run by the day under the Fiscal Procedure Code, Law 207/2015, in ANAF's consolidation to OUG 38/2026. Late-payment interest is 0.02% for each day of delay (art. 174(5)). A late-payment penalty of 0.01% a day comes on top of it and does not remove the interest (art. 176(2)-(3)).
Where ANAF assesses tax the company did not declare, a non-declaration penalty of 0.08% a day applies, reduced by 75% if the tax so assessed is paid in time (art. 181(1)-(2)). None of the three charges is deductible for profit tax (art. 25(4)(b) Fiscal Code).
Only for large companies, and only to the end of 2026. The impozit minim pe cifra de afaceri (IMCA, minimum turnover tax) applies to companies with previous-year turnover above EUR 50 million (art. 18^1(1) Fiscal Code). For fiscal year 2026 its rate is 0.5% within the formula of art. 18^1(3), a rate inserted by OUG 89/2025 (art. 18^1(16)), and the article applies up to and including 31 December 2026 (art. 18^1(17)).
One activity-based floor sits beside it: night clubs, casinos and similar businesses pay the greater of profit tax and 5% of the revenue from those activities (art. 18).

Profit that leaves the company as a dividend is taxed again. For dividends distributed from 1 January 2026, the rate is 16% whether the shareholder is a Romanian company (art. 43(2)), an individual, as a final tax (art. 97(7)), or a non-resident, by withholding (art. 224(4)(b)). The start date is set by Law 141/2025, art. VII(1)(a), (c) and (h); dividends distributed on interim statements drawn up in 2025 keep 10% (art. VII(2)).
Since Law 239/2025, a company whose net assets have fallen below half of its subscribed capital may distribute dividends from the current year's profit only after restoring them to the legal minimum, and one with a carried-forward loss only after setting up legal reserves and covering that loss (art. 69^1 Law 31/1990). Each route is set out in the guide on how much of a Romanian dividend reaches a foreign shareholder.
| Recipient | Rate | Relief | Article |
|---|---|---|---|
| Romanian company | 16% of the gross dividend | 0% where both companies pay profit tax and the recipient has held at least 10% for one full year at payment | art. 43(2), 43(4) |
| Individual | 16%, final | no relief in the article | art. 97(7) |
| Non-resident | 16%, withheld | the rate cannot exceed that of the applicable treaty | art. 224(4)(b), 230(1) |
| EU parent company | 0% | at least 10% held for an uninterrupted year ending at payment; the payer must pay profit tax | art. 229(1)(c) |
| Dividends on 2025 interim statements | 10% | the 2025 rate is kept | Law 141/2025 art. VII(2) |
Dividend tax by recipient, dividends distributed from 1 January 2026. Sources: the Fiscal Code, art. 43, 97, 224, 229 and 230; Law 141/2025.
Take 100 units of taxable profit at a company that pays profit tax. Profit tax at 16% (art. 17) takes 16, leaving 84. If all 84 are distributed to a non-resident shareholder, the 16% withholding (art. 224(4)(b)) takes 13.44, and 70.56 reaches the shareholder. That is before any relief: a treaty rate or the EU parent exemption changes the second step, and, where they apply, the net-asset and loss limits of Law 239/2025 come before any distribution.
Between Romanian companies, no dividend tax is due where both companies pay profit tax and the recipient has held at least 10% of the paying company for one full year at the payment date (art. 43(4)). An EU parent is exempt where it has held at least 10% for an uninterrupted year ending on the payment date, and only if the paying company pays profit tax without any option or exception (art. 229(1)(c)). Dividends paid by a micro-enterprise therefore do not qualify.
The rules are set side by side on the holding companies page.
For a non-resident shareholder, the rate applied cannot exceed the rate in the treaty that applies to that income (art. 230(1)). Which treaty applies, and to whom, is the subject of the double tax treaties guide.
For 2026, yes. The impozit pe construcții (construction tax) of Title X is owed by Romanian legal persons, except public institutions, national R&D institutes, associations, foundations and other non-profit bodies (art. 496(1)(a) Fiscal Code). In the 2026 text it is 0.5% of the net value of constructions not subject to building tax (art. 498(1)(a)).
It is declared by 25 May, paid in two equal instalments by 30 June and 31 October, and paying the whole year early earns a 10% bonus (art. 499(1), (2), (4^1)). From 1 January 2025 OUG 156/2024 set the tax at 1% of the value of constructions (art. 498(1) as amended), and Title X is repealed from 2027 according to ANAF's table of OUG 89/2025, which makes 2026 the last year it is due.
Separately, a company's non-residential buildings carry local building tax of 0.2% to 1.3% of taxable value a year, at the rate the local council sets (art. 460(2)).
Six acts, from OUG 156/2024 of December 2024 to OUG 8/2026, moved the figures on this page. Each row gives the date, the change, what it replaced and the act.
| Date | Change | What it replaced | Act |
|---|---|---|---|
| 1 January 2025 | dividend tax 10%; construction tax set at 1% of the value of constructions (art. 498(1) amended) | 8% on dividends, kept for 2024 interim dividends without recalculation | OUG 156/2024, Official Journal no. 1.334 of 31 December 2024 |
| fiscal year 2025 | micro ceiling EUR 250,000, tested at 31 December 2024 | the previous ceiling | art. 54(3) Fiscal Code |
| 1 August 2025 | VAT standard rate 21% | the previous standard rate | Law 141/2025, Official Journal no. 699 of 25 July 2025 |
| 18 December 2025 | Law 239/2025 in force | new act | Law 239/2025, Official Journal no. 1160 of 15 December 2025 |
| 1 January 2026 | dividend tax 16% for companies, individuals and non-residents | 10% | Law 141/2025 art. VII(1)(a), (c), (h) |
| 1 January 2026 | micro ceiling EUR 100,000; single micro rate 1%; IMCA 0.5% for 2026, ending 31 December 2026 | the EUR 250,000 ceiling; the previous micro rates | OUG 156/2024 (ceiling); OUG 89/2025 (single rate, IMCA 0.5%); art. 54(3) Fiscal Code |
| 1 January 2026 | art. 25^1: deduction of IP, management and consultancy fees to non-resident affiliates capped at 1% of total expenses | ordinary art. 25 deductibility | Law 239/2025 |
| 30 January 2026 (publication) | art. 25^1 repealed; ordinary deductibility from the first quarter of 2026 | the 1% cap | OG 6/2026, Official Journal no. 77 of 30 January 2026 |
| 25 February 2026 | 90 days for a new company to meet the employee condition; 3% bonus on 2025 annual tax | new rules | OUG 8/2026, Official Journal no. 147 of 25 February 2026 |
| 1 January 2027 | construction tax repealed | 0.5% in 2026 | OUG 89/2025 art. I pt. 52, per ANAF's table |
The fee cap is the row to read twice: it applied from 1 January 2026, and OG 6/2026, published on 30 January 2026, repealed it with ordinary deductibility restored from the first quarter of 2026.
Computing the fiscal result and preparing and filing a company's profit-tax and micro-tax returns inside an accounting contract is work of CECCAR-registered experts contabili and contabili autorizați (chartered and licensed accountants) and of CECCAR-approved firms. Performing it without authorisation is a criminal offence (OG 65/1994, art. 1, 6(a) and 43(1)).
Stand-alone tax advice, including representation before ANAF sold outside the accounting contract, is reserved to consultanți fiscali on the register of the CCF, the Chamber of Tax Consultants (OG 71/2001, art. 3(1)(e), 8(6) and 25(2)). On this site, profit tax and micro tax are handled only inside the accounting contract, by the CECCAR-registered accountants who perform it.
All consulted in October 2026.
Both rates exist, on different bases. Profit tax is 16% of taxable profit (art. 17 Fiscal Code). A company that meets the micro-enterprise conditions and opts for that regime pays 1% of its revenue instead (art. 51(1), 53(1)) and is then outside profit tax (art. 13(2)(h)). The two percentages are not comparable, because one taxes profit and the other revenue.
Two official texts disagree. Art. 42(1) of the Fiscal Code sets 25 June of the following year for form 101, the annual profit tax return. ANAF's forms page, citing OPANAF 206/2025, prints 25 March of the following year. This guide settles neither date; before filing, the accountant checks ANAF's fiscal calendar for the year in question.
It moves to profit tax from the quarter in which its revenue passes EUR 100,000 (art. 52(1)). The regime also needs an employee or a paid administrator, and one micro-enterprise per shareholder above 25% (art. 47(1)(g), (h)). A micro-enterprise cannot opt for profit tax during the fiscal year, only from the next one (art. 48(2^1)).
Yes, under the ordinary rule. Law 239/2025 capped the deduction of IP, management and consultancy fees to non-resident affiliates at 1% of total expenses from 1 January 2026 (art. 25^1). OG 6/2026, published on 30 January 2026, repealed the cap, and these costs follow ordinary art. 25 deductibility from the first quarter of 2026.
The profit tax rate is 16% of taxable profit, set by art. 17 of the Fiscal Code, Law 227/2015 as amended. This guide reads ANAF's consolidated text, last updated by Law 170/2026, which is a consolidation, not a republication. The micro-enterprise alternative is 1% of revenue under art. 51(1), a single rate since 1 January 2026.
A new SRL that opts for the micro regime and meets the capital and one-micro conditions at registration pays micro tax from registration if an employee, or an administrator paid at least the gross minimum wage, is in place within 90 days (art. 48(3), OUG 8/2026). Otherwise profit tax applies from the quarter after the 90 days expire.
The fiscal result is accounting revenue minus accounting expenses, minus non-taxable income and fiscal deductions, plus non-deductible expenses (art. 19(1)). Expenses for the business are deductible (art. 25(1)); protocol only within 2% (art. 25(3)(a)); the company's own profit tax and fines are not (art. 25(4)). Dividends from a Romanian company are non-taxable (art. 23(a)).
Yes. A tax loss from 2024 onwards is recovered over the next 5 consecutive years, against at most 70% of each year's taxable profit (art. 31(1)). Earlier losses follow the same 70% limit for what remains of their 7 years (art. 31(7)). A loss made before a micro period is recovered once the company returns to profit tax (art. 31(5)).
Profit tax is paid by the 25th of the month after quarters I to III (art. 41(1)). Alternatively, a company may pay annually with quarterly advances of one quarter of last year's tax, updated by the consumer price index (art. 41(2), (8)); not after a year of formation, loss, inactivity or micro tax (art. 41(6)).
Only for large companies. The minimum turnover tax (IMCA) applies where previous-year turnover exceeded EUR 50 million, at 0.5% within the statutory formula for 2026, and it applies up to 31 December 2026 (art. 18^1). Night clubs, casinos and similar businesses pay at least 5% of the revenue of those activities (art. 18).
Dividends distributed from 1 January 2026 are taxed at 16%, whether paid to a Romanian company, to an individual as a final tax, or to a non-resident (art. 43(2), 97(7), 224(4)(b); Law 141/2025). A treaty can cap the rate (art. 230(1)); an EU parent holding 10% for a year is exempt, but not on a micro-enterprise's dividends (art. 229(1)(c)).
Eligible R&D expenses carry an extra 50% deduction, with accelerated depreciation (art. 20(1)). Profit reinvested in technological equipment, computers and software is exempt (art. 22(1)). Sponsorship is credited against the tax, up to the lower of 0.75% of turnover and 20% of the tax due (art. 25(4)(i)). On 2025 tax, timely filers and payers receive a 3% bonus (OUG 8/2026).
For 2026, yes. The construction tax is 0.5% of the net value of constructions not subject to building tax (art. 498(1)(a)), declared by 25 May and paid by 30 June and 31 October (art. 499). ANAF's table of OUG 89/2025 records its repeal from 2027. Buildings also carry local building tax of 0.2% to 1.3% (art. 460(2)).
Dividend tax went to 10% in 2025 (OUG 156/2024) and to 16% from 2026 (Law 141/2025). The micro ceiling was EUR 250,000 for 2025 and is EUR 100,000 from 2026 (art. 54(3)). A 1% cap on fees to foreign affiliates was repealed within a month (OG 6/2026), and OUG 8/2026 grants a 3% bonus on 2025 tax paid on time.
Only on the business it carries on in Romania through one or more permanent establishments (art. 13(1)(b) Fiscal Code). Romanian legal persons pay profit tax under art. 13(1)(a), unless they pay the micro-enterprise tax (art. 13(2)(h)). Whether a particular activity creates a permanent establishment depends on the facts of the case and is not answered in this guide.