Fiscal Bulleitn - 13 January 2025

Amendments to Law no. 227/2015 regarding the Fiscal Code

Dividend tax

• Dividend tax is increased from 8% to 10%, starting with dividends distributed after January 1, 2025. The provisions apply to Romanian legal entities as well as individuals and nonresidents;

• It is mentioned that for dividends distributed on the basis of interim financial statements prepared during 2024, the dividend tax rate remains 8%. The tax on such dividends shall not be recalculated, after their regularization on the basis of the annual financial statements for the financial year 2024, approved in accordance with the law.

Micro-enterprise regime

• For the year 2025, the income threshold for the micro-enterprise regime is modified from EUR 500,000 to EUR 250,000. As from January 1, 2026, it will be modified to EUR 100,000;

• Clarifications are made concerning certain CAEN codes present in the specific microenterprise legislation that have been updated as of January 1, 2025, relevant from the perspective of the application of the 3% rate;

• From 2025 onwards, the condition that consultancy and management revenues must not exceed 20% of total revenues to benefit from the micro-enterprise regime is removed. Income tax and social contributions

• The fiscal facilities of employees working in the construction, agriculture, food and IT industries are eliminated as of January 1, 2025. Therefore, the wage income in these sectors will be subject to taxation and social security contributions under the general regime;

• In the case of employees with an individual employment contract employed on a fulltime basis, no income tax and social contributions are due for the amount of 300 lei/month applicable to income for the period January-December 2025, representing income from salaries and assimilated to salaries, if the following conditions are cumulatively met:

o The gross monthly basic salary, not including bonuses and other allowances, must be equal to the gross minimum salary in the country;

o The gross income from salaries and assimilated to salaries, excluding the value of meal vouchers, vacation vouchers, and food allowance, as the case may be, must not exceed 4,300 lei inclusive.

Construction tax

• The construction tax payable by certain legal entities is reintroduced, with a few changes from the previous form. Thus, as from January 1, 2025, this tax is calculated by applying a rate of 1% to the value of the constructions existing in the taxpayer's patrimony on December 31 of the previous year, minus the value of buildings for which building tax is owed;

• The tax is payable in two equal installments, by June 30 and October 31 respectively.