Last updated: April 2026
At a glance
Golden Visa status: Draft bill B490/2025 withdrawn from Parliament in December 2025 following a negative assessment by Romania’s Supreme Council of National Defence (CSAT). No Golden Visa law is currently in force.
Tax residency threshold: 183 days in any rolling 12-month period (Article 7, Romanian Fiscal Code). Residents are taxed worldwide; non-residents only on Romanian-source income.
PIT rate: 10% flat on most individual income categories (unchanged for 2026).
WHT on non-residents (from 1 January 2026): 16% on dividends, interest, and royalties under domestic law (Law 141/2025). Treaty and EU directive reductions may apply.
DTT network: ~86 active double tax treaties, including with Armenia, the US, UK, UAE, and major EU partners.
Schengen: Romania is a full Schengen member (air and sea borders from 31 March 2024; land borders from 1 January 2025).
Romania’s proposed Golden Visa drew attention because it paired EU residency benefits with what was described as an explicit no-minimum-stay rule. For globally mobile investors, this opened space for “non-dom style” planning — holding a residence permit without triggering worldwide taxation.
However, the legislative landscape has shifted significantly. The draft bill was withdrawn in December 2025, and Romania’s tax code has seen notable changes for 2026, particularly in withholding tax rates for non-residents. This guide covers what happened to the Golden Visa proposal, Romania’s current tax-residency framework, and the planning considerations that remain relevant for investors with Romanian ties.
Table of contents
- What happened to Romania’s Golden Visa: the CSAT withdrawal
- Romanian tax-residency tests: the 183-day rule and centre of vital interests
- NAFA registration: arrival and departure questionnaires
- Tax consequences: residents vs non-residents
- 2026 withholding tax rates and EU directive relief
- Double tax treaty access and the residency certificate requirement
- Schengen membership and EU mobility
- CRS, AEOI, and automatic exchange of information
- Action checklist for investors with Romanian ties
- Frequently asked questions
What happened to Romania’s Golden Visa: the CSAT withdrawal
Romania’s draft Golden Visa bill (B490/2025) proposed a renewable 5-year residence permit for a minimum investment of €400,000 in qualifying assets, including government bonds, real estate, authorized investment funds, and listed company shares. Reports indicated the draft included no mandatory annual stay requirement to maintain the permit.
In November 2025, the Supreme Council of National Defence (CSAT) issued a negative assessment of the program. The concerns centered on three factors: potential risks to Romania’s newly achieved Schengen Area membership, the country’s standing in the US Visa Waiver Program, and Romania’s OECD membership ambitions. Following the CSAT assessment, the bill was formally withdrawn from Parliament in December 2025.
As of April 2026, no Golden Visa law is in force in Romania. Ordinary investor immigration remains available through Romania’s aliens-law framework administered by the General Inspectorate for Immigration, though without the streamlined terms the Golden Visa draft proposed. For investors exploring alternative EU residency pathways, Romania’s company formation route and other European programs remain options worth considering — see our residence by investment overview for regional comparisons.
The tax-planning framework analyzed in the draft bill remains relevant, however. Investors who already hold Romanian assets, operate businesses in Romania, or are considering Romanian real estate continue to face the same tax-residency rules and withholding tax regime described below.
Romanian tax-residency tests: the 183-day rule and centre of vital interests
Under Article 7 of the Romanian Fiscal Code, an individual is generally treated as a Romanian tax resident if they are present in Romania for more than 183 days during any period of 12 consecutive months ending in the relevant calendar year. This is a rolling 12-month calculation, not a strict January-to-December count — a distinction that matters for investors planning travel patterns around year-end.
Beyond the day count, residency can also be established based on the individual’s centre of vital interests: where the main home, family, and principal economic activities are located. In cases of potential dual residency, double tax treaties apply tiebreaker tests — permanent home, centre of vital interests, habitual abode, and nationality — to determine a single treaty residence.
When does Romanian tax residency begin?
The commencement date depends on how residency is triggered. If an individual declares Romania as their centre of vital interests, tax residency begins from the exact date of the declaration. If residency is triggered by the 183-day physical presence test, it applies retroactively from the first day of arrival in the year the threshold is breached. This distinction can affect the scope of taxable income in the first year.
Planning tip: Maintain a contemporaneous travel log and documentary evidence of ties — housing contracts, family location records, business management location, and bank account activity. Mapping these factors annually is essential if your goal is to maintain non-resident tax status in Romania while holding investments or operating businesses there.
NAFA registration: arrival and departure questionnaires
Romania’s National Agency for Fiscal Administration (ANAF) requires individuals arriving in Romania to complete a fiscal residency questionnaire. This is not optional — the 183-day presence threshold triggers a mandatory reporting obligation, not merely an invitation to register.
Individuals who depart Romania and wish to formally break their tax residency must complete a separate departure questionnaire. Administrative fines of 50–100 RON apply for late filing of these questionnaires.
For investors planning to stay under the 183-day threshold, awareness of these administrative requirements is important. Even if you do not become a tax resident, Romania’s fiscal authorities expect compliance with reporting formalities when presence thresholds are approached.
Tax consequences: residents vs non-residents
The tax base shifts dramatically depending on residency status:
| Question | Romanian tax resident | Romanian non-resident |
|---|---|---|
| Scope of taxation | Worldwide income | Romanian-source income only |
| PIT rate | 10% flat on most categories | 10% on Romanian-source income under Title IV; 16% WHT under Title VI for certain payments |
| DTT access | Yes, with Romanian tax residency certificate | Generally no — may rely on home-country treaty instead |
| WHT on dividends (domestic rate) | 10% (resident individual) | 16% (from 1 January 2026) |
| Social security | 10% health + 25% pension on qualifying income above threshold | Generally not applicable unless Romanian employment or self-employment |
Romania applies a 10% flat personal income tax (PIT) rate to most categories of individual income, unchanged for 2026. Non-residents are only taxed on Romanian-source income — they are not subject to Romanian tax on foreign-source income provided they maintain non-resident status.
Practical examples of Romanian-source income include employment exercised in Romania, services rendered in Romania, Romanian real estate income, and gains derived from Romanian assets.
2026 withholding tax rates and EU directive relief
Effective 1 January 2026, Romania increased withholding tax rates on payments to non-residents under Law 141/2025 (amending Article 224(4)(b) of the Fiscal Code). The new domestic statutory rates are:
| Income type | 2026 domestic WHT rate | EU directive relief |
|---|---|---|
| Dividends | 16% | 0% under EU Parent-Subsidiary Directive (qualifying EU corporate parent with ≥10% holding for ≥1 year) |
| Interest | 16% | 0% under EU Interest & Royalties Directive (qualifying associated companies with ≥25% holding for ≥2 years) |
| Royalties | 16% | 0% under EU Interest & Royalties Directive (same conditions) |
The increase from prior rates is significant for investors receiving Romanian-source passive income without treaty or directive protection. Where a more favorable double tax treaty rate applies, Romania will apply the treaty rate instead of the domestic rate — but the recipient must provide proper documentation (typically a tax residency certificate from their home jurisdiction).
For corporate structures, the EU Parent-Subsidiary Directive eliminates withholding on dividends paid by a Romanian subsidiary to a qualifying EU parent company that holds at least 10% of the shares for a minimum of one year. The EU Interest and Royalties Directive offers similar relief for qualifying associated companies with at least 25% shareholding held for at least two years.
Double tax treaty access and the residency certificate requirement
Romania maintains approximately 86 active double tax treaties, covering major investment jurisdictions including the US, UK, UAE, Singapore, Israel, Armenia, China, Germany, and France. Treaty benefits typically require the individual to be a tax resident of one of the contracting states and to provide a valid tax residency certificate.
If your aim is non-resident status in Romania, you generally cannot rely on Romania’s DTT network to reduce Romanian withholding taxes — you will lack a Romanian residency certificate. However, you may access treaty relief through your home country’s tax residency by providing a residency certificate from your home jurisdiction, provided the treaty between your home country and Romania permits it.
Key treaty rates: Romania–Armenia
The Romania–Armenia double tax treaty has been in force since 1 January 1998. Under the treaty, the following reduced rates apply to Romanian-source income paid to Armenian tax residents: dividends at 5% (for holdings of 25% or more, subject to a 365-day holding-period condition following the MLI) or 10% (other cases); interest at 10%; and royalties at 10%. For investors structuring through Armenian entities or holding Armenian tax residency, these treaty rates significantly reduce the 16% domestic withholding. For background on Armenia’s tax framework, see our taxes in Armenia guide.
Recent treaty developments
A new UK–Romania double tax treaty was signed on 13 November 2024, entered into force on 23 December 2025, and became effective in Romania from 1 January 2026. Romania has also suspended its treaties with Belarus (from 12 November 2024) and Russia (from 14 October 2024).
Schengen membership and EU mobility
Romania became a full Schengen Area member in phases: air and sea border controls were lifted on 31 March 2024, and land border controls followed on 1 January 2025. This means Romanian residence permit holders now benefit from freedom of movement across the entire Schengen zone without border checks.
For investors, Schengen membership enhances the practical value of a Romanian residence permit — whether obtained through the ordinary investor immigration framework or a future version of the Golden Visa program, if the legislature revives it. However, a Romanian residence permit does not automatically grant the right to work in other EU member states; it enables travel within the Schengen area for up to 90 days in any 180-day period.
CRS, AEOI, and automatic exchange of information
Romania is fully compliant with the Common Reporting Standard (CRS) and the EU’s Automatic Exchange of Information (AEOI) framework, implemented through Law 207/2015 and Government Emergency Ordinance 102/2022 (DAC2 transposition). Romanian financial institutions report account information of non-resident account holders to the tax authorities of the account holder’s country of residence.
For investors who hold Romanian residence permits but maintain tax residency elsewhere, this means your Romanian bank accounts and financial assets will be reported to your home country’s tax authority. Proper self-certification of tax residency with Romanian financial institutions is essential to ensure accurate CRS reporting and avoid compliance issues in your home jurisdiction.
Action checklist for investors with Romanian ties
- Map your travel calendar against Romania’s 183-day rolling 12-month test. Remember this is not a calendar-year count — days accumulated in the preceding months carry forward.
- Decide your anchor tax residency and centre of vital interests. Avoid inadvertent dual residency by ensuring your primary home, family, and economic interests clearly point to one jurisdiction.
- Complete ANAF questionnaires on arrival and departure. Non-compliance carries fines of 50–100 RON, and failure to file may complicate future dealings with Romanian tax authorities.
- Confirm whether you want Romanian DTT access. If yes, plan to become a Romanian tax resident and obtain the residency certificate from ANAF. If no, plan for domestic 16% WHT on Romanian-source passive income and explore treaty relief through your home jurisdiction.
- Review cross-border payment chains for dividends, interest, royalties, and service fees. Pre-clear documentation with Romanian payers and ensure residency certificates are current.
- Evaluate corporate structuring opportunities using the EU Parent-Subsidiary Directive (0% WHT on qualifying dividends) and the Interest and Royalties Directive. These can eliminate the 16% domestic rate entirely for properly structured corporate holdings.
- Coordinate immigration and tax counsel and secure written opinions before committing to a structure. For broader second-home or citizenship planning, see our citizenship overview and real estate services.
