Amendments to the Fiscal Code

a. Dividend tax: starting 1 January 2025, the dividend tax rate increased from 8% to 10% for both residents and non-resident taxpayers. This applies to dividends distributed after 1 January 2025. For dividends distributed based on interim financial statements drawn up during the year 2024/modified tax year beginning in 2024, the applicable tax rate remains 8% (with no obligation to recalculate the dividend tax after adjustments based on the annual financial statements for the year 2024/modified year beginning in 2024).

b. Microenterprise income tax: the income threshold for the microenterprise tax regime has been modified as follows:

• EUR 250,000 starting from 2025 (based on income realised up to 31 December 2024)
• EUR 100,000 starting from 2026 (based on income realised up to 31 December 2025).

In addition, the requirement that a taxpayer generates more than 80% of its total revenue from activities other than consultancy and/or management in order to qualify as a microenterprise taxpayer has been eliminated as of 1 January 2025.

c. Personal income tax and social contributions: the income tax exemption and the reduced social security contribution rate for employees working in the IT, construction and agriculture sectors were eliminated as of 1 January 2025.

For 2025, full-time employees working at their primary workplace will benefit from income tax exemption and a reduction in the taxable base for social security contributions amounting to RON 300/month, provided the following conditions are met cumulatively:

• the gross monthly base salary, excluding bonuses and allowances, is equal to the national gross minimum wage applicable for the corresponding month of salary income. This condition is deemed not to have been met if the gross salary stipulated in the individual employment contract is reduced below the guaranteed minimum wage between 1 January 2025 and 31 December 2025
• the total gross monthly income, excluding meal vouchers, holiday vouchers or meal allowances applicable for the same month, does not exceed RON 4,300

The RON 300/month amount is adjustable depending on:

• the period of the month for which the minimum wage is kept at the guaranteed minimum level
• the date of employment on the minimum wage
• the period worked within the month
• the date of termination of the employment contract

d. Construction tax: starting with 2025, a 1% construction tax is to be levied on the value of constructions owned by taxpayers on 31 December of the previous year, excluding those already subject to building tax. This tax also applies to buildings located in industrial, science and technological parks that do not benefit from exemptions. The construction tax is payable in two equal instalments, due by 30 June and 31 October, respectively.

Source: Emergency Ordinance no. 156/2024 on various fiscal-budgetary measures in the field of public expenditure for the substantiation of the consolidated general budget for 2025, on the amendment and supplementation of various normative acts, as well as on the postponement of certain deadlines.