The 20th edition of the Annual Tax Conference organized by EY Romania, marking two decades of modern tax history, brought together over 200 representatives of the Romanian business community and authorities. The main topics of discussion focused on the evolution of the Romanian tax system and the important milestones achieved over the past decade, as well as recent legislative changes, tax increases for companies and individuals, and the digitization of the tax system.
EY Romania specialists provided detailed information and answers, such as principles and approaches, to help understand the challenges of 2026. The measures in the tax packages announced and approved last year, defined as part of a true tax revolution in Romania, will continue. Representing the authorities was Mr. Adrian Nicușor Nica, President of ANAF.
“The year 2026 follows a turbulent 2025 in many respects. However, last year ended better than many people expected in terms of finance and the budget. We entered 2026 with high hopes that it would be a calmer year from a legislative point of view and that it would be followed by another year where investors would see a return to normalcy through the elimination of IMCA and the stabilization of many other fiscal elements,” says Alex Milcev, Partner, Head of Tax and Legal Assistance Department, EY Romania.
Miruna Enache, Partner, Head of Transaction Tax Assistance Division, EY Romania, explained: “The transition from a bureaucratic, paper-dependent tax system to a digital architecture where communication, reporting, and risk analysis aim to be integrated in near real time, the introduction of the Virtual Private Space, the standardization of reporting formats, and the use of collected data for risk analysis have redefined the way taxpayers interact with the tax administration. Digitization is not just a technical modernization; it has changed the very nature of tax compliance.”
Outlook and expectations for 2026
Among the many aspects that the Romanian tax system needs to improve, several key issues have emerged. Controversies over transfer pricing remain a significant challenge for companies, particularly in the area of intra-group services and profit allocation.
“Against the backdrop of increasingly detailed analysis by the authorities, companies must ensure that they have solid documentation. At the same time, advance pricing agreements (APAs) are becoming an essential tool for preventing disputes and avoiding their escalation into litigation or amicable proceedings,” explained Adrian Rus, Partner, Transfer Pricing Department Leader, EY Romania.
On the other hand, legal assistance is essential in the area of tax audits and inspections in order to identify risks of non-compliance in a timely manner, but also opportunities in legislation, according to Emanuel Băncilă, Partner, Head of Tax Litigation and Controversy Practice, Băncilă, Diaconu şi Asociaţii SPRL.
The intersection between VAT and transfer pricing, the right to deduct, and VAT exemptions were also discussed, as these are areas in which the Court of Justice of the European Union (CJEU) has already established benchmarks with a direct impact on the results of tax inspections.
“In parallel with the integration of digital control tools—such as e-Invoice, SAF-T, e-Transport, and e-VAT—tax authorities are expanding their analytical capabilities without changing the legal standards applicable to VAT, excise duties, and other indirect taxes. For the business environment, these developments confirm the importance of an integrated approach to tax compliance, linking digital reporting to the economic reality of transactions,” explained Georgiana Iancu, Partner, Head of Indirect Tax and Tax Digitalization, EY Romania.
The good news includes this year’s reduction in IMCA and its elimination in 2027, which is a positive signal for the business environment, while the new deductibility limitations and the focus on controls, digitization, and transfer pricing require companies to prepare in advance.
“Ensuring proper compliance, in order to avoid inconveniences and potential undesirable consequences of tax audits, can only be achieved through effective tax risk management,” added Călin Stan, Partner at Băncilă, Diaconu și Asociații SPRL.
The changes announced in the area of taxation and labor relations also mark an important step towards accountability and transparency in the overall picture of the Romanian labor market. The new format of the Single Declaration, pre-filled from ANAF sources, is a step forward in digitization, but shifts the focus to the taxpayer, who will have to check and correct any errors, including by adding income from abroad. The European Directive on salary transparency brings significant reporting and internal policy review obligations, with real risks of penalties for non-compliance.
Stela Andrei, Partner, People Advisory Services, EY Romania: “The challenges in the area of labor and personal taxation will continue. The new measures for taxing passive income come amid pressure from international institutions to abandon the flat tax rate, with higher tax pressure on consumption, property, and capital gains. These changes are accompanied by the acceleration of digitization processes, new actions in the area of migration, the expansion of the automatic exchange of information between institutions and states, as well as tax inspections.”
Therefore, for this year and the years to come, the conclusion is as follows: rapid adaptation and investment in compliance by companies, as well as measures to digitize the Romanian tax system, are no longer optional, but a sine qua non condition for the development of the Romanian economy and the recovery of the gaps that still separate it from developed economies.