The impact of the new taxes on commercial companies in 2026 in Romania

How companies are affected by the new fiscal amendments starting in 2026

The tax changes applicable as of January 1, 2026 have a significant impact on the business environment in Romania and mainly concern the increase or recalibration of certain local and central taxes, changes in the calculation of tax on buildings, land and motor vehicles owned, as well as substantial changes in dividend tax and the micro-enterprise regime. These measures aim to increase budget revenues but generate additional costs and legal risks for each commercial entity, especially in the context of intensified tax inspections and tax disputes. This article analyzes the impact of the new taxes and duties on commercial companies in 2026, focusing on the main legislative changes and their practical consequences for businesses.

In this context, the Romanian Law Firm Pavel, Mărgărit and Associates, recognized for its extensive experience in tax law, commercial law, and business law, recommends seeking assistance from a commercial lawyer, business lawyer, or corporate lawyer, who can provide tailored legal support both for compliance with new fiscal requirements and for procedures related to company formation in Romania, open a company in Romania, set up a company in Romania, open a limited company, start a business in Romania, or starting up your own business in Romania, as well as representation in litigation lawyer in Romania matters and complex tax disputes.

Tax lawyer in Romania. Amendments to the building tax in 2026 for commercial companies

The legislative amendments applicable starting in 2026, in the context of the fiscal reform introduced by Law no. 239/2025, maintain the fundamental rules regarding the calculation of the building tax for legal entities, while significantly increasing the fiscal burden through higher local tax rates and strict reliance on the updated taxable value of buildings. According to Article 460 paragraph (1) of the Romanian Fiscal Code, for residential buildings owned or held by legal entities, the building tax is calculated by applying a rate ranging between 0.08% and 0.2% to the taxable value of the building, the specific rate being established by decision of the local council. At the level of Bucharest Municipality, this competence belongs to the General Council of Bucharest Municipality.

By the decision adopted for the year 2026 at Bucharest Municipality level, a tax rate of 0.2% was established for residential buildings owned or held by legal entities, and a rate of 1.5% for non-residential buildings. The taxable value is determined pursuant to Article 460 paragraph (6) of the Fiscal Code, based on the value recorded in the fiscal records, the value resulting from an appraisal report prepared by an authorized appraiser, the final value of construction works for newly built buildings, or the value indicated in ownership transfer documents. This taxable value must be updated every five years, and failure to comply triggers a punitive tax rate of 5%, subject to prior notification by the tax authority. In practice, these rules result in a significant increase in the tax assessment burden for companies, particularly for office buildings, commercial premises, and industrial facilities located in major urban areas.

In such circumstances, fiscal lawyer, lawyer for taxes, or litigation lawyer in Romania may provide legal assistance regarding the correct interpretation of fiscal regulations, representation before local authorities, and support during tax audits, including cases where companies disagree with a tax decision, through filing challenges against a tax decision, initiating administrative litigation to annul or suspend a tax assessment, and obtaining favorable tax court decision outcomes in complex tax disputes.

VAT lawyer in Romania. New Rules on the Taxation of Vehicles Owned by Legal Entities

Starting in 2026, the taxation regime applicable to vehicles owned by legal entities has been substantially amended, leading to a generalized increase in the fiscal burden. The legislation introduces a new calculation mechanism for vehicle tax, based on engine capacity, by multiplying each 200 cc unit or fraction thereof by a legally established amount, while public authorities will use an integrated data exchange system regarding pollution standards. The new regulation establishes distinct tax values depending on pollution standards (E0–E3, E4, E5, E6), whereby more polluting vehicles are taxed more heavily, and vehicles with higher standards benefit from comparatively lower values.

A significant amendment concerns hybrid vehicles. Previously, the tax reduction applied uniformly to all hybrid vehicles. Under the new regulation, the reduction is expressly conditional upon the vehicle having carbon dioxide emissions of no more than 50 g/km, thereby limiting the fiscal incentive strictly to low-emission hybrids. Moreover, the reduction is capped at a maximum of 30%, compared to the previous 50%. As a result, most companies owning hybrid vehicles will pay higher taxes than in previous years. At the same time, an annual fixed tax of RON 40 is introduced for electric vehicles, regardless of capacity or value.

To mitigate fiscal risks, a VAT lawyer, lawyer for taxes, or litigation lawyer in Romania can assist companies in reviewing documentation, liaising with tax authorities, and pursuing remedies when they disagree with a tax decision, including filing challenges against a tax decision, initiating court proceedings to annul or suspend a tax assessment, and securing protection against adverse tax court decision outcomes.

Financial lawyer in Romania. Taxation of land owned by companies and legal procedures for challenging unlawful tax decisions

The land tax owed by legal entities is determined annually in accordance with Article 465 of the Tax Code based on the land area, category of use, rank of the locality, and the area in which it is located, and the taxable value and amount of tax are determined by decision of the local council, within the limits provided by the Tax Code.

For land located within urban areas, the land tax varies according to the rank of the locality and the taxation zone, with fixed amounts applied per hectare or fraction thereof, differentiated between land with buildings and other categories of use. In the case of land located outside urban areas, the tax is calculated depending on the category of use, by applying statutory values adjusted by correction coefficients, without regard to zoning. Given that the establishment of taxable values and taxation zones falls under the authority of the local council, or in the case of Bucharest, the General Council of Bucharest Municipality, interpretative discrepancies or classification errors may lead to increased tax liabilities for companies.

For clarity, the following example is provided. A legal entity owns land located within the urban area of Bucharest, Sector 2, Zone B, Rank I, recorded in the agricultural register under the category “land with buildings.” According to Decision no. 514/2025 of the General Council of Bucharest Municipality, for urban land classified in Zone B, the tax is set at RON 13,528 per hectare. In this case, for 0.50 hectares, the initial tax amounts to RON 6,764. By applying the correction coefficient for Rank I, namely 5.00, the final annual land tax payable reaches RON 33,820. Such calculations are frequently contested through tax disputes, especially when companies disagree with a tax decision or challenge the legality of the tax assessment.

According to tax legislation, taxpayers who consider that the tax assessment issued by the tax authority is unlawful have the right to lodge an appeal within 45 days of notification. The appeal must contain the factual and legal grounds and be accompanied by supporting documents. After exhausting the administrative appeal, the taxpayer may file an action for annulment pursuant to Article 8 of Administrative Litigation Law 554/2004, targeting both the decision to settle the administrative appeal, on the grounds of procedural defects, errors of substance, or incorrect calculation. Furthermore, pursuant to Article 14 of Law no. 554/2004, the taxpayer may request suspension of the act pending judgment on the merits, which temporarily halts enforcement in Romania and prevents forced execution in Romania until the court issues a ruling. This legal framework offers effective protection against enforcement proceedings in Romania based on unlawful fiscal acts, often with the assistance of a company litigator in Romania, or tax litigation lawyer in Romania, and may culminate in a favorable tax court decision.

In such situations, a tax lawyer, commercial lawyer, or business lawyer based in Bucharest, specialized in fiscal and commercial litigation, can provide legal assistance in filing challenges against a tax decision, initiating administrative litigation, seeking annulment or suspension of fiscal acts, and addressing forced execution in Romania, including suspension of enforcement measures and filing challenges against enforcement proceedings in Romania, thereby safeguarding the assets of each company involved in tax disputes.

Company Lawyer in Romania. Dividend taxation, elimination of the 3% tax rate and reduction of the revenue threshold for microenterprises

Starting January 1, 2026, the dividend taxation regime has been amended by increasing the tax rate from 10% to 16%, pursuant to Article 43 paragraph (2) of the Fiscal Code. This amendment has a direct impact on entrepreneurs’ tax planning, as net income derived from dividend distributions is significantly reduced. Companies that structured their financial strategies based on the previous tax rates must reassess their budgets, taking into account the increased fiscal burden and the resulting reduction in cash flows available to shareholders.

At the same time, starting in 2026, the 3% tax rate applicable to microenterprises has been eliminated, and the revenue threshold for qualifying under this regime has been reduced from EUR 250,000 to EUR 100,000, pursuant to Article 47 letter c) of the Fiscal Code. While the elimination of the 3% rate may benefit microenterprises with revenues below the new threshold, exceeding this limit automatically triggers the application of the corporate profit tax regime, with significant fiscal consequences. From a legal standpoint, companies are required to carefully review contractual arrangements and adapt commercial clauses to the new fiscal framework, in order to maintain financial equilibrium and avoid non-compliance risks.

“These new fiscal measures must be addressed with utmost care in order to avoid financial imbalances and significant legal risks for any type of commercial company,” stated Dr. Radu Pavel, Managing Partner of the Romanian Law Firm Pavel, Mărgărit and Associates.

In conclusion, the new taxes and duties applicable as of 2026 significantly reshape the fiscal framework in which Romanian companies operate, affecting the taxation of buildings, land, vehicles, dividends, and the microenterprise regime. Adapting to these changes requires thorough legal analysis and a well-founded tax strategy. The Romanian Law Firm Pavel, Mărgărit and Associates recommends engaging a tax lawyer, fiscal lawyer, litigator in Romania, lawyer for taxes, commercial lawyer, or business lawyer, who can provide comprehensive legal assistance for compliance, dispute prevention, and the protection of economic interests, whether related to tax disputes, tax assessment, tax decision challenges, forced execution in Romania, or strategic matters connected to starting up your own business in Romania and company formation in Romania.

Pavel, Margarit and Associates Law Firm is one of the top law firms in Romania, providing high-quality legal services. The firm’s clients include multinational and domestic companies of great magnitude. In 2025, the law firm’s success stories brought it international recognition from the most prestigious international guides and publications in the field. As a result, Pavel, Margarit and Associates Law Firm ranked 3rd in Romania in the Legal 500’s ranking of business law firms with the most relevant expertise. The law firm is internationally recognized by the IFLR 1000 Financial and Corporate 2025 guide. Additionally, Pavel, Margarit and Associates Law Firm is the only law firm in Romania recommended by the international director of Global Law Experts in London in the Dispute Resolution practice area. All relevant information about Pavel, Margarit and Associates Law Firm can be found on the website www.avocatpavel.com.