Tax Compliance in Romania
Dividend tax computed, withheld, declared and paid inside the accounting contract, with forms 205 and 207. Tax Compliance in Romania
dividend tax
By Mihai Dumitrescu, VAT and tax compliance lead · Reviewed by Ioana Marinescu, Accounting and reporting client lead · Updated October 2026
Every tax rule on this page is read in the Fiscal Code as consolidated by ANAF to Law 170/2026.
Dividend tax in Romania, the impozit pe dividende, is 16% of the gross dividend for dividends distributed from 1 January 2026: for individuals as a final tax (art. 97(7)), Romanian companies (art. 43(2)) and non-residents (art. 224(4)(b)), under Law 141/2025. The paying company withholds it and pays by the 25th of the next month. In 2025 it was 10%.

A dividend leaves the company only after the accounts fix the profit, and the company withholds the tax on the day it pays.
The dividend tax rate in Romania is 16% for every kind of shareholder. Under art. 43(2), 97(7) and 224(4)(b) of the Fiscal Code, the tax is 16% of the dividend brut (gross dividend) paid to a Romanian company, to an individual, for whom it is an impozit final (final tax), and to a non-resident. The text read here is ANAF's consolidation of Law 227/2015 to Law 170/2026, a consolidation and not a republication.
For an individual the tax is final: the withholding settles the income tax on that dividend, and only the health contribution described further down can follow it. Computing, withholding, declaring and paying this tax belongs to the corporate tax returns for a Romanian SRL that an accounting contract covers.
| Recipient | Rate | How it works | Article |
|---|---|---|---|
| Individual shareholder | 16% of the dividend, final tax | the paying company computes and withholds it at payment | art. 97(7) |
| Romanian company | 16% of the gross dividend | withheld by the paying company; exemption possible under art. 43(4) | art. 43(2) |
| Non-resident, individual or company | 16% withholding | treaty or EU relief possible; converted into lei at the BNR rate of the payment day | art. 224(4)(b), 224(5) |
Dividend tax by recipient, dividends distributed from 1 January 2026. Sources: the Fiscal Code, ANAF consolidation to Law 170/2026; start date in Law 141/2025, art. VII(1).
Two layers sit on one profit. Profit tax, also 16%, is the company's own tax; the dividend tax is the second layer, charged on what is paid out to the owners. A dividend paid in foreign currency to a non-resident is converted into lei at the exchange rate of the BNR, the National Bank of Romania, for the day of payment (art. 224(5)). The exemptions and the treaty route follow further down.
The rate follows the date the dividend is distributed, not the year whose profit it comes from. Law 141/2025, published in Official Journal no. 699 of 25 July 2025, set 16% for dividends distributed from 1 January 2026 (art. VII(1)(a), (c), (h)). Before it, OUG 156/2024 art. LXIV, published in Official Journal no. 1.334 of 31 December 2024, set 10% for dividends distributed after 1 January 2025, in place of 8%.
| Period | Rate | Act and rule |
|---|---|---|
| Dividends distributed before 1 January 2025 | 8% | kept for 2024 interim dividends, without recalculation (OUG 156/2024, transitional article) |
| Dividends distributed after 1 January 2025 | 10% of the gross dividend | OUG 156/2024 art. LXIV |
| 2025 interim dividends, regularised on the 2025 annual accounts | 10%, not recalculated | Law 141/2025 art. VII(2) |
| From 1 January 2026, individuals | 16%, final | Law 141/2025 art. VII(1)(c); art. 97(7) Fiscal Code |
| From 1 January 2026, Romanian companies | 16% | Law 141/2025 art. VII(1)(a); art. 43(2) Fiscal Code |
| From 1 January 2026, non-residents | 16% | Law 141/2025 art. VII(1)(h); art. 224(4)(b) Fiscal Code |
| Company with a modified fiscal year | 16% from the first day of its modified fiscal year beginning in 2026 | Law 141/2025 art. VII(1)(a), (h) |
Interim dividends distributed during 2025 keep the 10% rate. Under Law 141/2025 art. VII(2), they are not recalculated once they are regularised on the 2025 annual accounts. The same rule applied a year earlier: interim dividends of 2024 kept 8% under the transitional article of OUG 156/2024, without recalculation.
A company whose fiscal year does not follow the calendar, an anul fiscal modificat (modified fiscal year), moves to 16% on a different day for its company and non-resident shareholders. Under Law 141/2025 art. VII(1)(a) and (h), the 16% applies from the first day of its modified fiscal year beginning in 2026.
The shareholder does not pay the dividend tax to ANAF: the company that pays the dividend computes, withholds, declares and pays it (art. 97(7) and 224(5) Fiscal Code).
The paying company computes the tax and withholds it at the moment the dividend is paid, for individuals (art. 97(7)) and for non-residents (art. 224(5)).
A dividend paid to a non-resident in foreign currency is converted into lei at the BNR exchange rate for the day the payment is made (art. 224(5)).
The tax is declared and paid to the state budget by the 25th, inclusive, of the month after payment (art. 43(2), 97(7), 224(5)), on form 100.
For dividends approved during the year and still unpaid at year end, the tax is paid by 25 January of the next year (art. 43(3); the same rule in art. 97(7) and 224(5)).
No tax is computed, withheld or paid on dividends distributed but unpaid at year end where an EU parent meets the exemption at year end (art. 224(5)).
By the last day of February of the next year, the company files the annual informative return per beneficiary: form 205 or form 207 (art. 132(2), 231(1)).
law a term set by law
Accounts approved, distribution decided
The shareholders
Residence certificate handed over
A non-resident, to the paying company; an EU parent adds the OMFP 583/2016 declaration
Payment and withholding
The paying company: 16%, the treaty rate, or nothing where an exemption is documented
Form 100, tax paid
The paying company
Approved but unpaid at year end
The paying company
Annual informative return
Form 205 (residents) and form 207 (non-residents)
Resident individuals CASS in the single return by 25 May of the next year, art. 122(3)
Three forms carry the dividend tax, all filed with ANAF. Form 100 is the return for every payment obligation to the state budget (ANAF forms catalogue), filed for the month the tax falls due. Form 205 reports resident beneficiaries and covers dividends (art. 132(2) Fiscal Code); form 207 reports non-resident beneficiaries, exempt income included, on the model of OPANAF 179/2022 (art. 231(1)). An EU parent claiming the exemption hands the paying company the declaration of OMFP 583/2016 before payment.
| Obligation | Who | Deadline | Article or form |
|---|---|---|---|
| Compute and withhold the tax | the paying company | at payment of the dividend | art. 97(7), 224(5) |
| Declare and pay | the paying company | by the 25th, inclusive, of the month after payment | art. 43(2), 97(7), 224(5); form 100 |
| Dividends approved in the year, unpaid at year end | the paying company | tax paid by 25 January of the next year | art. 43(3); same rule in art. 97(7) and 224(5) |
| Foreign-currency dividend to a non-resident | the paying company | converted at the BNR rate of the payment day | art. 224(5) |
| Annual informative return, resident beneficiaries | the paying company | by the last day of February, for the previous year | art. 132(2); form 205 |
| Annual informative return, non-resident beneficiaries, exempt income included | the paying company | by the last day of February, for the previous year | art. 231(1); form 207, OPANAF 179/2022 |
| EU exemption declaration | the EU parent, to the paying company | with the residence certificate, before payment | OMFP 583/2016 form |

Company law comes before tax. A dividend is the share of profit paid to each shareholder (art. 67(1) Law 31/1990), and it may be paid only from profit determined by law (art. 67(3)). That profit is fixed by the approved annual accounts, whose deadline is set out in the filing deadline guide. Before a distribution, these conditions apply:
A dividend paid from profit not determined by law, or not split by paid-up capital (art. 67(2), (3)), is returned if the company proves the shareholders knew, or should have known, of the irregularity; the recovery action is time-barred 3 years after the distribution (art. 67(5)). The shareholders approve the distribution by resolution. They may sign a standard resolution themselves; a bespoke one is a lawyer's drafting (Law 51/1995, art. 3(1)(c) and 3(2)).
Law 239/2025, published in Official Journal no. 1160 of 15 December 2025 and in force from 18 December 2025, added limits to Company Law 31/1990 that decide whether a distribution is lawful before any tax is computed.
| Rule | Content | Article |
|---|---|---|
| Only from profit | dividends only from profit determined by law | art. 67(3) |
| Legal reserve | at least 5% of profit a year until one fifth of the capital; applies to SRLs | art. 183(1), 201(2) |
| Carried-forward loss | current-year profit distributable only after the legal reserves and covering the carried-forward loss | new art. 69^1(1) |
| Net assets below half the subscribed capital | no distribution from current profit until net assets are restored; no interim dividends meanwhile | new art. 69^1(2), (3) |
| Quarterly interim dividends | allowed on interim financial statements, regularised within 60 days of approving the annual accounts | art. 67(2), 67(2^2) |
| Shareholder loans | no loans to shareholders or affiliates until the interim dividends are regularised | new art. 67(2^3) |
| Joint liability | where a loan ban is breached, company and shareholder jointly liable for the company's tax arrears, up to the amount lent or repaid | new art. 67(2^5) |
| Fine | 10,000 to 200,000 lei for breaching the loan bans, applied by ANAF | new art. 67(2^6) |
Dividends may be paid quarterly, on situații financiare interimare (interim financial statements), under art. 67(2) Law 31/1990. The differences are settled within 60 days of approving the annual accounts, and shareholders repay any excess within the same 60 days (art. 67(2), (2^2)).
Until the interim dividends are regularised, the company may not lend to its shareholders or affiliates (new art. 67(2^3)). Where the company lends in breach of that ban, or repays shareholder loans while its annual accounts show net assets below half the subscribed capital, company and shareholder are jointly liable for its tax arrears up to the amount lent or repaid (art. 67(2^5)), and ANAF fines a breach of either ban 10,000 to 200,000 lei (art. 67(2^6)).
Current-year profit becomes distributable only after the legal reserves are set aside and the pierdere contabilă reportată (carried-forward accounting loss) is covered (new art. 69^1(1) Law 31/1990). While the activ net (net assets) stays below half the subscribed capital, nothing is distributed from current profit until net assets are restored to the legal minimum, and no interim dividends are paid meanwhile (art. 69^1(2), (3)).
Two exemptions exist, one for a Romanian parent company and one for an EU or EEA parent. Both turn on the size of the holding, how long it has been held and the tax status of the company paying the dividend. Where an exemption applies, the paying company withholds nothing but still reports the payment: form 207 lists non-resident beneficiaries, exempt income included (art. 231(1)).
| Relief | Conditions as written | Article |
|---|---|---|
| Domestic participation exemption (Romanian company recipient) | the recipient holds at least 10% of the paying company for one full year up to and including the payment date; both companies pay profit tax without option or exception | art. 43(4)(a)(i), (a)(iii), (b)(ii) |
| EU parent exemption | the parent holds at least 10% of the capital for an uninterrupted period of at least one year ending on the payment date; the paying Romanian company pays profit tax under Title II without option or exception; the form and tax conditions of the article are met | art. 229(1)(c), point 3(ii) |
| EEA parents | the same exemption for Iceland, Liechtenstein and Norway | art. 229(1)(c^1) |
| Anti-abuse | the exemption is refused where the arrangement is not put in place for valid commercial reasons reflecting economic reality | art. 229(2) |
| EU parent, dividend distributed but unpaid at year end | no tax computed, withheld or paid where the parent meets the exemption at year end | art. 224(5) |
Which rate applies to this dividend?
Start: a dividend distributed from 1 January 2026. Who receives it?
Resident individual
final tax
Romanian company
at least 10% for one full year; both companies pay profit tax?
EU or EEA company
at least 10% for an uninterrupted year; payer pays profit tax; valid commercial reasons?
Any other non-resident
residence certificate at payment?
The rules, not a recommendation for any case.
A dividend paid to a Romanian company is exempt where the recipient holds at least 10% of the paying company for one full year up to and including the payment date (art. 43(4)(a)(i) Fiscal Code). Both companies must pay profit tax without option or exception (art. 43(4)(a)(iii), (b)(ii)), so the exemption fails where either of them is a micro-enterprise. The exemption is a rule of the code; how a group is organised around it is a separate subject, covered in the holding company guide listed at the end.
A dividend paid to a parent company in another EU state is exempt where the parent holds at least 10% of the capital for an uninterrupted period of at least one year ending on the payment date, the paying Romanian company pays profit tax under Title II without option or exception, and the parent meets the form and tax conditions of the article (art. 229(1)(c), point 3(ii)). Parents in Iceland, Liechtenstein and Norway have the same exemption (art. 229(1)(c^1)).
The exemption is refused where the arrangement is not put in place for valid commercial reasons that reflect economic reality (art. 229(2)). Before payment, the parent hands the paying company the exemption declaration of OMFP 583/2016 together with its tax residence certificate.
Dividend tax computed, withheld, declared and paid by CECCAR-registered accountants, forms 205 and 207 included.
A microîntreprindere (micro-enterprise) pays tax on its revenue, not profit tax, and when it pays dividends it applies the ordinary rules of art. 43 (art. 57(2) Fiscal Code). The regime itself is described in the micro-enterprise tax guide. Both exemptions require the paying company to pay profit tax (art. 43(4)(a)(iii), (b)(ii) and art. 229(1)(c) point 3(ii)), so the dividends of a micro payer qualify for neither, whoever the parent is.
For a foreign parent of a micro SRL, the relief that remains is the treaty rate: the Romanian rate cannot exceed it (art. 230(1)), provided the residence certificate is handed over at payment, as the next section sets out. The law attaches this consequence to the regime; it does not choose the regime for the company.
Before a dividend is paid, inside the accounting contract, we check four things: the paying company's tax regime for the year, each shareholder's residence and holding, whether the residence certificate and, for an EU parent, the exemption declaration are on file before the payment date, and whether the year's profit clears the Law 239/2025 limits.
Mihai Dumitrescu, VAT and tax compliance lead
The Romanian rate cannot exceed the rate of the applicable double tax treaty, and for an EU resident the most favourable of domestic law, EU law and the treaty applies (art. 230(1) Fiscal Code). ANAF's treaty list names 90 partner countries, Andorra the newest from 1 January 2026. The relief is not automatic:

The Romania-Germany treaty of 4 July 2001, ratified by Law 29/2002, shows how a cap works. Under its art. 10(2)(a), Romania may tax the dividend at no more than 5% where the beneficial owner is a company, other than a partnership, holding directly at least 10%; in all other cases the cap is 15% (art. 10(2)(b)). Germany is one illustration only: each treaty's own text sets its rate.
The domestic 16% is withheld first. When the certificate arrives, the treaty or EU rate is applied and the tax is regularised within the limitation period (art. 230(2) Fiscal Code). Tax withheld in excess is refunded under the Fiscal Procedure Code (art. 230(4)). ANAF's form for it is the regularisation declaration and refund request of OPANAF 765/2022, listed in its forms catalogue.
For the credit in the home country, any non-resident may apply to ANAF for the certificate attesting the tax paid to the state budget (art. 232(1)). The paying company also reports the non-resident beneficiary on its form 207 for the year, exempt income included, by the last day of February of the next year (art. 231(1)).
For a Romanian resident individual the 16% is final (art. 97(7)), but dividends also enter the base of the contribuția de asigurări sociale de sănătate (CASS, the health contribution) under art. 156 and 170 of the Fiscal Code. The individual's other income and the single return in general are covered in the income tax guide. The CASS rules on dividends:
Because the base is a flat band, the contribution does not rise with each further dividend inside a band; it changes only when the year's income reaches the next band (art. 170(3)). Who owes CASS is listed in art. 153(1): first Romanian citizens with domicile or residence in Romania, then foreigners with extended temporary residence or domicile in Romania.
Three things are often read as the dividend tax and are not.
An individual's liquidation proceeds above the contribution to the company's capital are taxed under a separate rule, at 10% as a final tax (art. 97(5) Fiscal Code).
The 10% of art. 224(4)(c^1) covers non-dividend income of individuals resident in the EU or a treaty state; dividends to non-residents stay at 16% under letter (b). More on withholding on dividends, interest and royalties.
Profit tax is the company's own tax, not a tax on the dividend. Selling shares produces a capital gain, not a dividend: see capital gains of individuals and companies in Romania.
Computing, withholding, declaring and paying the dividend tax, and filing forms 100, 205 and 207, 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 on distributions, 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 the dividend tax is handled only inside the accounting contract, by the CECCAR-registered accountants who perform it.
All consulted in October 2026.
For dividends distributed from 1 January 2026 the rate is 16% of the gross dividend, whether the shareholder is an individual (art. 97(7), final tax), a Romanian company (art. 43(2)) or a non-resident (art. 224(4)(b)). Law 141/2025 set it. The 10% rate applied to dividends distributed in 2025, and 8% applied before that.
No. The Romanian rate cannot exceed the treaty rate (art. 230(1)), but the non-resident must hand the paying company a tax residence certificate from the home tax authority at the moment of payment (art. 230(2)). Without it, the company withholds 16% and the treaty rate is applied later, when the certificate arrives.
No. When the certificate arrives, the treaty or EU rate is applied and the tax is regularised within the limitation period (art. 230(2)). Tax withheld in excess is refunded under the Fiscal Procedure Code (art. 230(4)). ANAF's form for the claim is the regularisation declaration and refund request approved by OPANAF 765/2022.
No. A micro-enterprise pays tax on revenue, not profit tax, and applies the ordinary dividend rules of art. 43 (art. 57(2)). Both exemptions require the paying company to pay profit tax (art. 43(4)(a)(iii), (b)(ii) and art. 229(1)(c) point 3(ii)), so its dividends qualify for neither. For a foreign parent, a treaty rate under art. 230(1) remains.
Only from current-year profit, after the legal reserves are set aside and the carried-forward loss is covered (new art. 69^1(1) Law 31/1990, added by Law 239/2025, in force 18 December 2025). While net assets are below half the subscribed capital, nothing is distributed from current profit until they are restored (art. 69^1(2)).
16% of the gross dividend for dividends distributed from 1 January 2026, for individuals, Romanian companies and non-residents alike (art. 97(7), 43(2) and 224(4)(b) of the Fiscal Code). For individuals the tax is final. The paying company withholds it. The change came with Law 141/2025, Official Journal no. 699 of 25 July 2025.
Dividends distributed after 1 January 2025 were taxed at 10% of the gross dividend (OUG 156/2024 art. LXIV); before that the rate was 8%. Interim dividends distributed in 2025 keep 10%, without recalculation, after their regularisation on the 2025 annual accounts (Law 141/2025 art. VII(2)).
The company that pays the dividend computes and withholds the tax at payment, then declares and pays it by the 25th of the following month (art. 43(2), 97(7), 224(5)), on form 100. If dividends approved during the year are still unpaid at year end, the tax is paid by 25 January of the next year (art. 43(3)).
Romanian residents may also owe the health contribution, CASS, at 10% (art. 156), on dividends net of the tax withheld. It is owed once investment and other non-salary income reaches 6 gross minimum wages, on a flat base of 6, 12 or 24 minimum wages (art. 170(2), (3)), declared in the single return by 25 May of the next year.
It can be. The parent must have held at least 10% of the capital for an uninterrupted year ending on the payment date, meet the form and tax conditions of art. 229(1)(c), and the Romanian payer must pay profit tax. The exemption is refused where the arrangement lacks valid commercial reasons reflecting economic reality (art. 229(2)).
Yes, on interim financial statements (art. 67(2) Law 31/1990), with differences settled within 60 days of approving the annual accounts. Until then the company may not lend to shareholders or affiliates (art. 67(2^3)). No interim dividends are paid while net assets are below half the capital (art. 69^1(3)). ANAF fines a loan-ban breach 10,000 to 200,000 lei (art. 67(2^6)).
Form 100 for the monthly declaration and payment of the tax. Then, by the last day of February of the next year, the annual informative return per beneficiary: form 205 for resident beneficiaries (art. 132(2)) and form 207 for non-resident beneficiaries, including exempt income (art. 231(1)). An EU parent claiming exemption also hands over the OMFP 583/2016 declaration.
A non-resident may ask ANAF for the certificate attesting the tax paid to the Romanian state budget (art. 232(1) of the Fiscal Code); it is the proof for the credit at home. The paying company also reports the payment to a non-resident on form 207, by the last day of February of the next year.
No. For an individual, proceeds received on liquidation above the contribution to the company's capital fall under a separate rule: they are taxed at 10%, as a final tax (art. 97(5) of the Fiscal Code). The 16% rate applies to dividends, the share of profit paid to each shareholder (art. 67(1) Law 31/1990).