In the first months of this year, the business environment in Romania faced two important challenges: on the one hand the fiscal controls were intensified, and on the other hand were imposed fiscal changes that directly affect the activity and budgets of the taxpayers.
Tax inspections intensify. Photo archive
In 2025, the tendency to increase the number of fiscal controls continued, being targeted all the fields of activity (logistics, production, services, etc.) and all taxpayers, both legal and natural persons, considers TPA Romania specialists, a company in Central and Eastern Europe, specialized in accounting, taxation, financial audit and legal consulting.
According to the performance report published by ANAF, in 2024 over 21,000 tax inspections were carried out, up 2.8% compared to 2023. About 75% of them targeted legal entities, and the remaining 25% targeted natural persons. The additional fiscal obligations imposed totaling 5.56 billion lei – an almost double value compared to the previous year, of which 98% were set for companies. For natural persons, the additional amounts were about 0.1 billion lei, similar to 2023.
“In parallel with fiscal inspections, ANAF has intensified other types of control actions, such as unexpected controls, anti-fraud controls, documentary checks, checks has the personal tax situation, or fiscal risk analysis.“, Explained Daniela Zar, Tax Partner within TPA Romania.
According to ANAF data, in 2024 over 29,000 documentary checks were carried out, of which about 21,000 in companies and 8,000 in individuals. Although the number of these checks increased by about 45% compared to 2023 (from just over 20,000), the amounts collected decreased by over 15%, to 850 million lei, compared to 1.03 billion lei in 2023.
“Among the frequently concerned areas of controls carried out by the fiscal authorities are transport, commerce and processing industry – sectors perceived as having high fiscal risk. Among the recurrent non -conformities are the unjustified VAT deduction, the lack of supporting documents for the services purchased and the adjustments of the transaction values due“Added the specialist.
SAF-T, e-facing and their impact in controls
Accelerating the digitization of the relationship between taxpayers and ANAF is one of the factors that have influenced the intensification of tax controls of the last period. This digitalization process was accelerated in 2024, and continues at a sustained rhythm this year: the SAF-T (D406) statement has also become mandatory for small taxpayers, the e-facing system has expanded to B2C transactions, and the E-TVA system adds a new level of complexity in the taxpayers' tax conformity. These tools provide fiscal authorities with quick and centralized access to accounting and fiscal data, allowing the automatic identification of discrepancies and initiating targeted controls. In this new context, discrepancies or omissions in tax reports are no longer unobserved, and taxpayers are frequently called to present explanations and supporting documents, in some cases being subject to tax inspections, explains the TPA Romania specialist.
“For companies, these obligations involve additional investments in compatible computer systems, personnel training and, above all, a rigorous verification of internal reporting procedures. Respecting the standards imposed by digitalization becomes essential not only for compliance, but also for avoiding the risk of controls. It is recommended to check the internal procedures periodically, the training of the personnel responsible for reporting, the use of accounting systems that can generate correct statements and reports, as well as a rigorous collection and archiving of the supporting documents. For many organizations, however, the lack of resources, whether financial or human, remains a significant obstacle to adapting to the new requirements ”says Daniela Zar.
2025 tax changes: What has changed and who is affected
The year 2025 has brought a series of incumbent fiscal changes, such as the tax regime applicable to micro-enterprises, increased dividend taxation, elimination of facilities for certain categories of employees or the so-called “pillar tax”.
One of the most discussed measures, which in particular affected the activity of local entrepreneurs, is the reduction of the ceiling for micro -enterprises from 500,000 euros to 250,000 euros in 2025, following a new decrease of the ceiling to 100,000 euros to take place from January 1, 2026. complex, but also higher costs of accounting and fiscal compliance and significantly higher chelux with profit tax.
In addition, the dividend tax increased from 8% to 10%, which directly affects the yield of investments.
Also, the IT, construction, agriculture and food industry were affected by the elimination of fiscal facilities, with a significant impact on the salary costs and the competitiveness of the companies in these sectors.
In parallel, the construction tax (“pillar tax”) was introduced, which amounts to 0.5% for those constructions that are not subject to buildings tax, respectively to 0.25% for constructions belonging to the state. The tax is due to the net accounting value of the constructions, but there are a number of unclear in terms of the concrete application of this tax.
Another fiscal modification concerns the companies that are part of large groups, with global revenues of over 750 million euros: they face for the first time, in 2025, with the quite complex calculations arising from the legislation on ensuring a global minimum tax of multinational enterprises and large national groups (Law no. 431/2023). Specifically, these calculations have the role of establishing whether the Romanian companies, part of these groups, owe an additional tax for 2024. This tax, if due, will be paid in addition to the usual profit tax. As a peculiarity, this additional tax refers to 2024 and is determined on the basis of individual and/or consolidated financial statements, but it will be declared and paid until June 30, 2026.
In the opinion of the TPA Romania specialist, for companies, all these changes involve adjusting budgets, remuneration policies or development plans. “The SMEs that risk coming out of the micro regime must evaluate if they can bear the additional cost of profit tax or will restrict their activity, depending on the profit margins they can generate. The companies affected by the fiscal changes are forced to identify the possibilities of financing the new taxes, all the more so as they were not known to the time,”
What follows
Romania has adopted the same direction that we see in other countries in the region-digitization and expansion of the tax base-but we continue to face a greater degree of legislative unpredictability and with tax changes announced and applied in a very short time.
“In the coming years, we expect the digitalization and automation of fiscal processes to continue at an accelerated rate. ANAF will integrate more and more data sources-from fiscal, banking, customs-into a centralized system, meant to automatically identify taxpayers with risk. Controls will become better directed, in particular, in particular.
In the next period, after the formation of the new government, and under the conditions of an increased budget deficit, we expect to be launched in public debate a package of fiscal changes. We cannot anticipate at this time what the changes will be, but It is expected that the tax pressure will increase, ”concludes the expert.
