Newsletter no. 6 – June 2026

Note: Starting in 2026, Nowium Newsletters are published only in the web version (without PDF), in both Romanian and English.

Summary

1. Transfer pricing file for 2026 – draft ANAF order (INFO)
2. Procedure for holding meetings between ANAF and taxpayers by videoconference (Order 705/2026)
3. Modalities for conducting the mutual agreement procedure for avoidance/elimination of double taxation (Order 660/2026)
4. Procedure for communicating alert notifications regarding non-fulfilment of budgetary payment obligations (Order 758/2026)
5. Update of Form 112 following GEO No. 89/2025 and GEO No. 8/2026 (Order 605/95/928/2314/2026)
6. Amendment of the procedure for solving contestations in the field of authorization of operators with excisable products (Order 676/2026)
7. Month-end foreign exchange rates for June 2026
8. Social indicators

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INFO – Transfer pricing file for 2026 (draft ANAF order): annual submission in SPV and thresholds per affiliate

On 10 June 2026, ANAF published for public consultation a draft order that rewrites the rules on the transfer pricing file – the first major restructuring since Order No. 442/2016. The draft addresses both the preparation and presentation obligations and content requirements. Among the new elements, we note:

• Annual submission of the transfer pricing file – mandatory for large taxpayers.
• Revised materiality thresholds – correlated with risk analyses; the draft significantly amends the value thresholds that trigger the documentation obligation, both for large taxpayers and for small and medium-sized ones.
• Clarification of the rules for benchmarking studies – a new geographical order for searching comparables is introduced, differentiated according to the tested party.
• Stricter transparency requirements and significant content changes, aiming to transform the file into an operational tool for continuous monitoring, giving inspectors permanent access to the information relevant for risk analyses.

The draft applies to transactions carried out starting from 1 January 2026 – a fiscal year already in progress. Consequently, the documentation of 2026 transactions will need to be planned and prepared as soon as possible, based on the new requirements.

For more information, please read our detailed article:

Dosarul prețurilor de transfer din 2026 (proiect): depunere anuală în SPV și praguri pe fiecare afiliat

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Order 705/2026 approving the Procedure for holding meetings between the central fiscal authority and taxpayers by using remote video communication means – meetings with ANAF by videoconference (Official Gazette No. 494/2026)

Summary

The procedure for organizing and holding remote meetings between the central fiscal authority and taxpayers has been approved, through the videoconference platform made available by the Ministry of Finance and ANAF (MF-ANAF). The procedure regulates the electronic identification methods of participants, the access conditions, the rules for holding the meetings, as well as the categories of fiscal procedures that may be carried out by videoconference. The provisions entered into force on 17 June 2026.

Details

• Who may participate: taxpayers registered in the Virtual Private Space (SPV) who express their option to hold the meeting in this format.
• Exercising the option: ANAF sends the information through SPV, and the taxpayer has 2 working days to opt; failure to observe the deadline is equivalent to not opting for videoconference (forfeiture). In the cases provided by law, taxpayers may request, through SPV, the postponement of meetings, providing justification.
• Procedures that may be carried out by videoconference: the initiation and conduct of the tax inspection and of the verification of the personal fiscal situation; the final discussion related to these; hearings on the rejection of refund/reimbursement or payment rescheduling requests; hearings on the single fiscal group (VAT) and the fiscal group for corporate income tax; hearing for the documentary verification; audience; mediation. The list may be extended with other legal procedures and/or procedural stages, in which case ANAF publishes the updated list on its portal 10 days before these can be conducted through the MF-ANAF videoconference platform.
• Identification of participants: authentication with the qualified certificate associated with SPV account, via NPOTP (username, password and OTP code) or via the ROeID platform.
• Prior documents: the taxpayer transmits through SPV the identification details of the participants and, where applicable, the power of attorney signed electronically. Changing participants is possible only if the documents are communicated at least 3 working days before the meeting.
• Conduct: one working day in advance, ANAF transmits through SPV the access link and the participation rules. Participants connect no more than 10 minutes before the set time, use a device with a functioning camera and microphone, and keep the camera on for the entire duration of the meeting.
• Prohibitions: recording, photographing, audio-video capturing or distributing the content of the meeting without the express consent of MF-ANAF is prohibited.
• Technical issues: if the videoconference is interrupted for technical reasons independent of ANAF’s will, the fiscal authority sets a new date and time, communicated through SPV.
• Recording of meetings: all meetings are recorded and transcribed, and the minutes and the other resulting documents are communicated to the taxpayer through SPV.

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Order 660/2026 on the modalities for conducting the mutual agreement procedure – solving double taxation under tax conventions (Official Gazette No. 497/2026)

Summary

The Order regulates the modalities for conducting the mutual agreement procedure in the field of the avoidance/elimination of double taxation, applicable under the double taxation conventions concluded by Romania with other states, as well as under Convention 90/436/EEC on the elimination of double taxation in connection with the adjustment of profits of associated enterprises. The procedure is used when the taxpayer considers that a fiscal measure may lead to taxation not in accordance with the provisions of the applicable convention.

Details

• Content of the request: the details of the persons involved, the fiscal jurisdictions concerned, the legal basis invoked, the periods and amounts subject to double taxation, as well as the description of the situation that generated the fiscal dispute. In the case of transfer pricing adjustments, additional details are required regarding the transactions between the affiliated persons and the relevant analysis thereof (functions, risks, assets, transfer pricing method, level of remuneration, etc.).
• Statements and disclosures: the applicant presents its point of view on the fiscal situation, mentions any ongoing administrative or judicial procedures and submits statements on its own responsibility regarding the accuracy of the information provided and the existence or non-existence of any means of appeal in connection with the contested administrative acts.
• Submission deadline: 3 years from the communication of the fiscal administrative act or of the relevant notification; if the deadline provided by the applicable convention is shorter, it is extended to 3 years.
• Submission method: mainly through SPV, in electronic format (PDF and editable), in both Romanian and English; in addition, the request may also be filed in hard copy with ANAF. A copy is transmitted simultaneously to the competent authority/authorities of the state(s) concerned.
• Procedural deadlines: ANAF notifies receipt of the request within 30 days; it may request additional information/documents within 90 days, and the taxpayer has 90 days to respond.
• Resolution: if the competent authorities reach an agreement, it is implemented by issuing a decision on the resolution of the mutual agreement procedure, approved by order of the ANAF President. For procedures based on Convention 90/436/EEC, if the authorities do not reach an agreement within the prescribed deadline, the affected person may request the initiation of the arbitration procedure.

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Order 758/2026 approving the Procedure for communicating alert notifications regarding the non-fulfilment of budgetary payment obligations – warning professional debtors with arrears (Official Gazette No. 526/2026)

Summary

The procedure for communicating the “Alert notification regarding the non-fulfilment of budgetary payment obligations” has been approved, together with its template. The notification serves to warn professional debtors of the existence of circumstances that could give rise to a state of difficulty or insolvency, signalling the need to act without delay to settle the outstanding obligations.

Details

• Addressees: professional debtors, namely legal entities, associations and entities without legal personality, persons registered with Trade Register, as well as individuals who carry out independent economic activities or exercise liberal professions.
• Threshold and frequency: the notification is communicated once upon reaching the threshold of RON 40,000 inclusive of outstanding budgetary obligations and, subsequently, twice a year (every 6 months), until full payment or until the arrears fall below this threshold.
• Excluded categories: debtors in insolvency or pre-insolvency; educational units and institutions and research entities; credit institutions, investment firms and other financial institutions; insurers and reinsurers; central counterparties and central securities depositories; administrative-territorial units and public institutions financed entirely by the state; individuals (non-traders); companies under special administration; associations and foundations (including NGOs).
• Communication method: by remote electronic means, namely through SPV. The notification is not communicated when the debtor simultaneously records outstanding obligations and undistributed amounts or amounts to be refunded.
• Support instruments included: the notification also presents the available support instruments – the mediation procedure, payment rescheduling (classic and simplified form), as well as the guidance and assistance services offered to taxpayers.

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Order 605/95/928/2314/2026 approving template, content, submission and management methods of Form 112 “Declaration regarding the payment obligations of social contributions, income tax and the nominal record of insured persons” – update of Form 112 (Official Gazette No. 463 bis/2026)

Summary

A new template and content for Form 112 “Declaration regarding the payment obligations of social contributions, income tax and the nominal record of insured persons” has been approved, in order to align it with the legislative amendments introduced by GEO No. 89/2025 and GEO No. 8/2026. The new provisions apply starting with the declaration of income for July 2026.

Details

The main amendments to Form 112 are the following:

• Non-taxable amount of RON 200/month: the declaration is correlated with the new fiscal regime applicable to the non-taxable amount of RON 200/month granted to employees during 1 July – 31 December 2026. Accordingly, Annex No. 1.2 “Insured person annex” was amended to reflect the replacement of the non-taxable amount of RON 300/month with the amount of RON 200/month, according to GEO No. 89/2025.
• Non-taxable income (Section E.3): the information on income benefiting from non-taxable fiscal treatment, within the legal ceiling of 33% of the base salary or of the monthly pay/salary granted according to the law, has been updated.
• “Insured type” nomenclature: it was updated by renaming the categories corresponding to codes 1.11.2 and 1.11.3, in accordance with the provisions of GEO No. 89/2025.
• Completion instructions: they have been revised to reflect the new fiscal and reporting provisions applicable starting with July 2026.
• Transitional regime: for the reporting periods between 1 January 2026 and 30 June 2026 inclusive, the previous Form 112 continues to be used (approved by Order No. 2,066/248/1,377/3,103/2025), the references to art. LXVI of GEO No. 156/2024 being deemed to be made to art. III of GEO No. 89/2025.

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Order 676/2026 amending Order of the Minister of Public Finance No. 3,004/2017 on the Procedure for solving contestations provided by Law No. 227/2015 on the Fiscal Code – contestations in the field of authorization of operators with excisable products (Official Gazette No. 512/2026)

Summary

The Order amends Order of the Minister of Public Finance No. 3,004/2017, which regulates the procedure for solving contestations lodged by economic operators against decisions issued in the field of authorization in matters of excisable products (tax warehouses, registered consignees, registered consignors, authorized importers).

Details

• Administrative means of appeal: the economic operator who considers itself wronged in its rights by a decision of the issuing authority may lodge a contestation, requesting the re-examination of the contested decision, in the sense of revoking or amending it.
• Form and deadline: the contestation is lodged in writing, with the issuing authority, within 30 days from the communication of the act, under sanction of forfeiture, and includes the identification details of the contester, the object, the reasons of fact and of law, the evidence and the signature of the entitled person.
• Resolution: the contestation file is transmitted to the specialized directorate within the Ministry of Finance; the contester may request, only once and within 20 days from registration, the oral hearing of the contestation (in person or online). The resolution decision is final within the system of administrative means of appeal and may be challenged before the competent administrative litigation court.

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Closing exchange rates for June 2026

The foreign exchange rates communicated by the National Bank of Romania and used for the June 2026 month-end closing for the valuation of monetary asset and liability items denominated in foreign currency (cash balances, receivables, liabilities), as well as for the valuation of receivables and liabilities denominated in RON whose settlement depends on the exchange rate of a foreign currency, are as follows:

1 EUR	1 USD	1 CHF	1 GBP
5,2438 RON	4,6010 RON	5,6828 RON	6,0897 RON

Please note that in the “Resources” section of our website you can find an Excel utility through which exchange rates are automatically retrieved from the NBR website and allocated to each validity date, in accordance with the accounting rules. The month-end closing rate is the foreign exchange rate communicated in the last foreign exchange session of the respective month.

Resources

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Social Indicators 2026

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