Through Government Emergency Ordinance (GEO) No. 89/2025, the Romanian Government establishes a firm timeline for the elimination of the tax on special constructions, commonly known as the “pole tax”. According to the new provisions, 2026 will be the last fiscal year in which this tax is due, with the regime being fully repealed as of 1 January 2027.
The repeal is expressly provided for in Article I point 52 and Article II of GEO No. 89/2025, published in the Official Gazette, and targets Title X of the Fiscal Code, which currently regulates this tax.
Elimination Timeline
The legislation introduces a clear and predictable schedule for taxpayers:
- 1 January 2027 – official repeal of Title X of the Fiscal Code and elimination of the tax on special constructions;
- for taxpayers applying a fiscal year different from the calendar year, the repeal applies starting with the fiscal year commencing during 2027;
- throughout 2026, the current rules remain in force, including declaration and payment obligations.
Who Remains Liable to Pay in 2026
Until the definitive abolition of the tax, taxable persons remain Romanian and foreign legal entities holding in their assets constructions classified under Group 1 of the Fixed Assets Catalogue. These mainly include constructions not subject to local building tax, such as:
- drilling wells and platforms;
- energy transmission and distribution networks;
- towers and communications infrastructure;
- irrigation channels and other similar technical constructions.
Tax Rates and Final Payment Obligations
For 2026, the tax rates remain unchanged:
- 0.5%, applied to the net value of constructions held in the taxpayer’s assets as of 31 December of the previous year;
- 0.25%, applied to constructions belonging to the public or private domain of the state or local administrative units, which are administered, concessioned, or used by the taxpayer and are not subject to local building tax.
Key deadlines for the final year of application are:
- 25 May 2026 – submission of the annual tax return;
- 30 June 2026 – payment of the first instalment (50%);
- 31 October 2026 – payment of the second instalment (50%).
Context and Economic Impact
The reintroduction of the “pole tax” through GEO No. 156/2024, applicable as of 1 January 2025, was strongly contested by the business community, being perceived as a tax that penalizes investments in infrastructure and productive assets. A similar tax had previously been applied during 2014–2016.
The current decision to abolish the tax reflects pressure from business organizations and the conclusions of impact studies, which highlighted that this tax:
- discourages investments and infrastructure modernization;
- generates limited budget revenues, disproportionate to the administrative costs and negative economic effects.
By repealing the tax, the authorities send a signal of fiscal predictability, offering companies a more favorable framework for investment planning starting in 2027.