Multinational enterprise (MNE) groups with operations in Romania have entered the final month available for voluntary alignment with Country-by-Country Reporting (CbCR) requirements, as tax authorities intensify scrutiny and expand taxpayer outreach. The awareness campaign launched in mid-November targets constituent entities of MNE groups, urging them to review their obligations under Government Ordinance 42/2017, which introduced CbCR in Romania.
CbCR obligations apply to ultimate parent entities resident in Romania and, in specific cases, to constituent entities when certain conditions are met. The annual report discloses data on revenues, profits, taxes paid, and employees across all jurisdictions in which the group operates. The purpose is to enhance fiscal transparency and allow tax administrations to better identify risks related to base erosion and profit shifting.
Globally, the relevance of CbCR is strengthened by OECD’s 2025 Corporate Tax Statistics, which now incorporate anonymised information from more than 8,700 MNE groups. The data shows that while misalignments between profit location and actual economic activity persist, their magnitude appears to decline. Nonetheless, many jurisdictions report receiving too few CbC filings to produce statistically robust contributions, reinforcing the importance of accurate reporting at the contributor level.
Romania faces additional complexity stemming from incomplete mechanisms for the automatic exchange of reports from non-EU jurisdictions. Consequently, Romanian entities belonging to groups headquartered outside the European Union must file locally using Form R404 and its dedicated XML schema, unless another EU jurisdiction already exchanges the corresponding report with Romania.
The consequences of non-compliance are substantial. Penalties may reach up to 20,000 euros, and taxpayers risk being classified at a higher fiscal risk level, which increases the likelihood of further audits. This risk is amplified by the recent launch of tax inspections covering more than 500 Romanian companies, signalling elevated attention from the authorities.
For taxpayers whose fiscal year ends on 31 December 2024, the CbCR submission deadline is 31 December 2025. The immediate priorities are assessing whether the reporting obligation applies and accelerating data collection to meet the statutory deadline. Voluntary compliance supports smoother interaction with tax authorities and reduces exposure to sanctions, while improving overall tax certainty.