Under the Legislative Themes section, the topic “Establishment of a Corporate Income Tax Group in 2026” was discussed, outlining the current fiscal framework and applicable requirements.
📅 Application Deadline
To establish a corporate income tax group effective from 1 January 2026, taxpayers must submit an application to the National Agency for Fiscal Administration (ANAF) by 2 November 2025.
🧾 Composition of the Tax Group
According to current regulations, a corporate income tax group must consist of at least two eligible entities, such as:
- a Romanian legal entity or a legal entity with its registered office in Romania established under European legislation, together with one or more Romanian legal entities over which it holds at least 75% of the shares or voting rights;
- at least two Romanian legal entities owned, directly or indirectly, by a Romanian individual holding a minimum of 75% of the shares or voting rights;
- at least two Romanian legal entities held, directly or indirectly, in at least 75% proportion, by a legal or natural person resident in a country with which Romania has concluded a double taxation treaty or an information exchange agreement;
- at least one Romanian legal entity owned, directly or indirectly, in at least 75% proportion, by a foreign legal entity resident in a country with which Romania has a double taxation treaty or information exchange agreement, together with the permanent establishment in Romania of that foreign entity.
⚙️ Review Procedure
The competent tax authority must review and resolve the application within 45 days from receipt and record it in a special register.
If the documentation is incomplete, the authority will notify the group’s responsible legal entity, which must complete the file within 15 days.
If the documentation is not completed, before rejecting the request, the tax authority ensures the right of the taxpayer to be heard, in accordance with Article 9 of the Tax Procedure Code.
Once all conditions are met, the authority issues Form 174, confirming the establishment of the group.
🏢 Communication of the Decision
If the members of the tax group are administered by different tax offices, a copy of the approval decision will be sent to each competent authority managing the respective member.