The Government of Romania has adopted Emergency Ordinance no. 156/2024 (GEO no. 156/2024, known as the “Little-Train Ordinance”), that was published in the Official Gazette No. 1334 on 31 December 2024, which introduces new measures for fiscal consolidation and combating tax evasion.
Dividend tax
The tax rate applicable for the dividends distributed as of 1 January 2025 increased from 8% to 10%.
Income tax and social security contributions
The income tax exemption on salary income and income assimilated to salaries derived by individuals who carry out software development activities, work in constructions, agriculture or the food industry was eliminated.
Starting January 2025 income, the tax benefits that previously exempted employees in the software development, construction, agriculture, and food industry from paying income tax and contributions to privately managed pension funds for gross monthly earnings up to RON 10,000 have been removed.
The Research and Development industry still benefits from income tax exemption.
The amount of RON 300, for full-time employees remains exempt from tax and social contributions, under certain conditions (i.e. at the main workplace of the employee, certain limits to be considered when other benefits are granted etc.)
Tax on microenterprise income
Starting 1 January 2025, for a legal entity to be classified as a microenterprise, the income realized on 31 December of the previous tax year must not exceed the equivalent in RON of EUR 250,000 (previously EUR 500,000). As of 1 January 2026, the limit of the realized income will decrease to EUR 100,000, for a legal entity to be classified as a microenterprise.
The condition of obtaining income from consultancy/management revenues in a proportion of over 80% of the total income of the microenterprise was eliminated.
Also, as of 1 January 2025, the list of CAEN codes for microenterprises has been expanded.
Other general provisions
The Government’s Emergency Ordinance No. 128/2024 provides that for determining the annual social security and health fund contributions due, the value of the minimum gross national salary valid on 1 January of the year (e.g. 4,050 RON for 2025) the income is earned shall be considered, in case during a tax year several gross minimum wages are applicable.
Starting 1 January 2025, the national minimum gross salary for a normal work schedule increased from RON 3,700 to RON 4,050 (9.4% increase), as per the Governmental Decision No. 1056/2024.
For a deeper discussion on the above, please reach out to your Vialto Partners point of contact, or alternatively:
Irina Marinescu
Director
Raluca Stancila
Manager
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