Romania has almost all the pieces of an alternative tax dispute resolution system (mediation, advance rulings, advance pricing agreements, administrative challenge), but no mechanism that actually works. A study in tax and comparative law: what can be negotiated with the Romanian tax authority, how the alternatives look in five European states, and what should change.
Who must declare income earned abroad, why Romania taxes it, how the tax credit and exemption methods work, and why the Romanian tax authority finds out about it anyway through the automatic exchange of information (CRS, DAC2, FATCA).
From 1 July 2026, steel importers must prove the country where the steel was actually melted and poured, not just the country of purchase. Tariff quota cut to 18.3 million tonnes, out-of-quota duty raised to 50%, burden of proof shifts to the importer.
In its judgment of 13 May 2026, the Court of Justice of the European Union clarifies the boundary between direct taxation (transfer pricing) and VAT, since a margin adjustment does not, in itself, become the consideration for a taxable supply.
The tax rate on income whose source cannot be identified during a personal tax situation verification has risen from 16% to 70%, a clear signal from ANAF on the importance of documenting the source of every sum.