Template of the form "Notification regarding the obligation to declare and pay the domestic top-up tax” has been published in the Official Gazette

On July 9, 2025, the template of the form 'Notification regarding the obligation to declare and pay the domestic top-up tax” has been approved through Order 1729/2025 and published in the Official Gazette no. 646.

We reiterate that, in accordance to the provisions of Law no. 431/2023 for ensuring a global minimum taxation level for multinational enterprises groups and large-scale domestic groups, the domestic top-up tax is to be declared and paid by each constituent entity located in Romania.

Groups with at least two constituent entities in Romania may opt for assigning a single entity (in its quality as a designated constituent entity) which to fulfill the declaring and payment obligations of the top-up tax on behalf of all other local constituent entities.

This simplification measure of the reporting and payment obligations is optional (not mandatory) and can be exercised by submitting the form „Notification regarding the obligation to declare and pay the domestic top-up tax” within 6 months since the last day of the financial reporting year.

For entities with a financial year corresponding to the calendar year, the deadline for submitting the notification was 30 June 2025.

As per the filing instructions, reporting entities will need to use the PDF electronic form with XML attachment, which will subsequently need to be signed electronically and submitted on e-guvernare portal.

Currently, the PDF form is not available on NAFA website.

We recommend companies with the financial year ending 31 December 2024 to submit the notification as soon as possible, even if the official deadline has been passed.

For more information, the EY team is at your disposal.