19 November 2025 Romania | CbCR in the spotlight — Tax authorities launch awareness campaign for voluntary compliance with 31 December 2025 deadline
For the first time, on 13 November 2025, Romanian tax authorities launched an awareness campaign encouraging Romanian constituent entities to verify compliance with the country-by-country reporting (CbCR) requirements and to ensure timely submission of the reporting due on 31 December 2025 for fiscal year ending on 31 December 2024. Voluntary compliance with disclosure obligations promotes smoother interactions between taxpayers and tax authorities and reduces exposure to penalties, which may vary depending on the circumstances. Apart from monetary penalties, failure to comply with CbCR disclosure requirements may increase a taxpayer's tax risk-assessment profile and trigger additional tax examinations. According to the tax authorities' statement, complying with CbCR requirements supports global efforts against tax evasion and fosters a transparent and fair international tax environment. Romanian constituent entities of multinational enterprise (MNE) groups headquartered outside the European Union (EU) and meeting the consolidated revenue threshold of €750m that do not perform a secondary EU filing of the country-by-country report (CbC Report) are required to file. The CbC Report must be filed within 12 months after the last day of the MNE group's reporting fiscal year. For fiscal years ending 31 December 2024, the deadline is 31 December 2025. Form R404 and related XML schema requirements applicable in Romania are to be used for electronic submission of CbC Reports. The Public CbCR (PCbCR) is a distinct reporting obligation under Romanian accounting regulations that must be made publicly available. It applies to Romanian and non-EU/European Economic Area (EEA) multinational groups with consolidated turnover exceeding RON 3.7 billion Romanian New Leu (RON3.7b) (approx. €747m) for each of the previous two consecutive financial years, as reflected in consolidated financial statements. Entities in scope include Romanian ultimate parent companies, standalone entities, medium and large subsidiaries controlled by a non-EU/EEA ultimate parent and branches of entities outside the EU. Entities must publish their PCbCR on their website within 12 months from the balance sheet date (e.g., for fiscal years ending 31 December 2024, the deadline is 31 December 2025), and submit the same to Romanian authorities. If financial statements are audited, the audit report will mention whether an entity was required to publish its PCbCR for the prior year and whether it complied with the requirement. Affected entities should immediately assess the CbCR and PCbCR requirements applicable to their Romanian presence. In preparation for meeting Romanian CbCR and PCbCR obligations, entities must focus on gathering necessary data. Finally, in-scope entities must ensure timely filing by 31 December 2025 of the CbCR and PCbCR filings for years ending on 31 December 2024. Interested parties should consult their tax advisors for assistance and help answer any further inquiries.
Document ID: 2025-2322 | ||||||
