At the beginning of 2026, we informed you about a significant tax reform enacted by the Romanian legislature, introducing a new limitation on the deductibility of certain intra-group expenses.
Under this measure, taxpayers with turnover below EUR 50 million (not subject to the minimum turnover tax, i.e., IMCA) were allowed to deduct expenses related to intellectual property rights and management and advisory services received from non-resident affiliated parties only up to 1% of total expenses, with any excess being treated as non-deductible for corporate income tax purposes.
The measure has now been repealed.
Through Government Ordinance no. 6/2026 published on 30 January 2026, the Romanian legislature fully abolished this deductibility limitation. As a result, starting in Q1 2026 / FY 2026, expenses previously falling under the 1% cap are once again subject to the general deductibility rules under Article 25 of the Fiscal Code.
