Romania’s second major package of tax changes as of 2026 has recently passed constitutional review by the Constitutional Court (CCR). The law implementing the tax changes was published in the Official Gazette on 15 December 2025. This means that, together with the previous package, these changes will significantly reshape the Romanian tax landscape for both individuals and companies.
The new measures introduce higher taxes (for certain types of income, as well as for properties), stricter compliance rules, revised valuation mechanisms for property taxation, and updated procedures for corporate governance and tax administration.
Below, we break down all relevant tax changes as of 2026 which are part of this second package. We explain what they mean in practice and how they will impact taxpayers.
One of the most impactful tax changes as of 2026 is the reclassification of income earned from short-term rentals and accommodation services (apart-hotel regime). Previously, if an individual rented up to 5 rooms under apart-hotel regime, the income was taxable based on an annual income norm system. If the number of rooms exceeded 5, they had to apply the taxation based on actual expenses (deduct all actual expenses incurred before calculating the income tax due).
As of 2026, this system will change: if an individual rents more than 7 rooms located in personal residential properties, these revenues will be classified as income from independent activities. If up until now such income was subject to taxation either based on the annual income norm or based on the actual expenses system, the rules will change starting with 2026. Taxpayers will no longer be allowed to apply these systems. They will have to apply a lump-sum tax deduction of 30% from the gross annual income.
Practical implications for taxpayers:
Which leads us to another important tax modification as of 2026 – i.e., the introduction of an additional higher threshold for paying health insurance contribution on freelancing activities.
Starting 2026, the maximum CASS threshold and calculation base for freelancing income increases to 72 national minimum gross wages (in 2025 the maximum threshold is 60 minimum gross wages).
This will generate higher health insurance contributions for taxpayers with substantial freelancing income as of 2026.
Another central area of change are the capital gains tax changes (income generated from the sale of securities). Below is a clear comparison between current capital gain tax rates and those that will be applicable under the tax changes as of 2026.
Current regime in 2025:
Income tax is withheld at source by the broker on all gains, while losses (if any) cannot be used for offset.
Regime applicable as of 1 January 2026:
This represents a tripling of the long-term rate and a doubling of the short-term rate.
Current regime:
Regime applicable as of 1 January 2026:
This could make international platforms significantly less tax-efficient compared to Romanian brokers, if one does not have significant losses to offset the gains.
Current regime:
Regime applicable as of 1 January 2026:
One of the most significant tax changes as of 2026 is the substantial update of taxable values for residential buildings, as per Article 457(2) of the Tax Code.
Example (Building Type A – reinforced concrete or brick structures with full utilities):
This will result in approximately 2.68-fold increase in the taxable base, which will increase the final property tax due with up to 80%.
Impact:
Also, the government has taken the decision for property registers to be streamlined through the national e-Property system.
The tax changes as of 2026 introduce also a major increase in the luxury tax applied to high-value assets (residential properties and cars).
Taxable assets:
Tax rate change:
This is actually threefold increase in the annual luxury tax that was applicable in 2025.
Multinational groups not falling under the IMCA system will face strict deductibility limitations on:
This aims to discourage profit shifting and increase transparency for intra-group transactions.
Companies exceeding the EUR 50 million turnover threshold (thus subject to IMCA) will be exempt from these limitations.
Key corporate law changes include:
In addition:
will be subject to stricter rules to prevent undercapitalisation of companies and mitigate tax evasion.
For companies with outstanding tax liabilities, the transfer of shares by controlling shareholders becomes opposable to the tax authority. This will allow the tax authority (ANAF) to track and challenge such transactions for preventing artificial avoidance of enforcement.
According to the new rules, any outstanding tax liabilities will have to be settled within 60 days from the registration of the share transfer to the Registry of Commerce. Otherwise, the guarantees provided will be enforced by the tax authority.
A company may be declared inactive if:
After one year of inactivity, dissolution becomes mandatory.
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