Law No. 239/2025, published in the Official Gazette no. 1160 of 15 December 2025, introduces Fiscal Package 2, reshaping key tax rules applicable from 2026. The amendments affect corporate income tax, personal income tax, social contributions, investments, and high-value assets, reflecting a stronger tax compliance approach.
New limitations apply to the deductibility of expenses paid to non-resident affiliated entities for IP, management, and consultancy services. Deductibility is capped at 1% of total expenses, subject to specific exemptions. Additional retention rules apply to companies in the oil and gas sector.
For individuals, short-term rentals are reclassified depending on the number of rooms rented, with a 30% flat-rate deduction and 10% income tax.
Investment income is taxed at source at 3% or 6%, depending on the holding period, while annual net capital gains are subject to a 16% tax. Cryptocurrency gains are also taxed at 16%.
The maximum CASS ceiling increases to 72 gross minimum wages, and the special tax on luxury assets rises to 0.9%.