International Tax Treaties of Romania 2026: Rates, Credits and How to Claim Them

Last reviewed: November 2026 · Reviewed by Stéphane Gombauld, tax expert, technologist and digital nomad

You earn income across borders and Romania is one of the countries involved, as home or as source. This guide explains how Romania's tax treaties decide who taxes what in 2026, how to claim reduced rates and credits, and which paperwork makes the difference.

Romania international tax treaties in 2026: the key figures

Is this guide for you?

Read on if you…

• live in Romania and receive salary, dividends, interest or rent from abroad;
• are a non-resident paid by a Romanian company or client and want the reduced withholding rate;
• are moving between Romania and another country and need the tie-breaker rules.

Probably not your case if you…

• only earn Romanian salary from a Romanian employer with no foreign income;
• want the residence tests themselves, which are in tax residency in Romania.

What do Romania's tax treaties actually do?

A double tax treaty is a contract between two states that splits the right to tax each type of income. Romania follows the OECD Model in most treaties signed since the 1990s, with older texts, for example with the US (1973) and the UK (1975), still in force.

Three things a treaty settles:

1. Residence tie-breaker. If both countries claim you as resident, the treaty looks in order at your permanent home, your centre of vital interests (basically where your life is), your habitual abode and your nationality. Romania applies this before its domestic tests.
2. Allocation. Salary is taxed where the work is done unless you stay under 183 days and are paid by a non-resident employer without a local establishment. Business profit is taxed where you are resident unless you have a permanent establishment in the other state. Property income is taxed where the property is. Dividends, interest and royalties are shared, with a cap on the source country's withholding.
3. Relief. Romania uses the credit method in almost all treaties: you pay Romanian tax on worldwide income and subtract the foreign tax, up to the Romanian tax on the same income. A few older treaties use exemption with progression for specific income.

Since 1 June 2022 the OECD Multilateral Instrument modifies most Romanian treaties with a principal purpose test: a treaty benefit is denied if obtaining it was one of the main reasons for an arrangement. Letterbox holding companies are the target.

How do you claim a reduced withholding rate on Romanian income?

Romania withholds 16% on dividends (up from 10% in 2025), interest, royalties, commissions and most service fees paid to non-residents. Treaties and EU directives cut this, but only if the Romanian payer holds your paperwork when it pays.

Procedure for a non-resident

1. Obtain a tax residence certificate from your home tax authority for the current year. Romania accepts the original or a certified copy, translated into Romanian if required.
2. Give it to the Romanian payer, with a statement that you are the beneficial owner. The certificate covers the year of issue and the first 60 days of the next year.
3. The payer applies the treaty rate or the EU exemption and declares you in its annual withholding return.
4. No certificate at payment time? The payer withholds 16%. You can still claim a refund from ANAF within the 5-year limitation period by filing the certificate later.

Treaty withholding rates on Romanian dividends, interest and royalties

For how the 16% interacts with Romanian corporate tax, see corporate income taxes in Romania.

How do Romanian residents get credit for foreign tax?

If you are resident in Romania, under the tests in practical guide to obtaining your tax residency in Romania, you declare foreign income in the Declarația unică by 25 May of the following year. For each country you compute:

• the Romanian tax on that income (10% for salary, rent and gains, 16% for dividends);
• the foreign tax actually paid, documented by a foreign tax certificate or withholding statement;
• the credit, which is the lower of the two.

Here's the catch: the credit never exceeds Romanian tax. If Germany withheld 26.375% on dividends, Romania credits only 16% and the rest must be reclaimed in Germany under the treaty's 15% cap. Also, the credit works per country and per income type, so excess credit from one country cannot offset tax on income from another.

For salaries earned abroad while resident in Romania, the treaty normally gives the work country the taxing right once you exceed 183 days there, and Romania credits that tax. Remote work for a foreign employer from Romania is the reverse: the work is done in Romania, so Romania taxes the salary in full and the employer's country should not.

How investment income is taxed before the credit is explained in capital gains tax in Romania.

What about social security and information exchange?

Treaties do not cover social contributions. Two other frameworks do:

• EU Regulation 883/2004: you pay contributions in one member state only. Posted workers and multi-state workers use an A1 certificate issued by the National House of Public Pensions (CNPP). A remote employee living in Romania and working for a German company normally pays Romanian CAS and CASS, not German contributions, unless an A1 says otherwise.
• Bilateral social security agreements with non-EU countries such as Turkey, Moldova, Canada, Quebec, Israel, South Korea, Serbia, Albania and Uruguay, which total contribution periods and avoid double contributions.

On transparency, Romania applies the OECD Common Reporting Standard and the EU DAC rules, so ANAF receives foreign bank, platform and, from 2026, crypto-exchange data. Romania also has a FATCA agreement with the US. The enforcement side is in tax fraud regulations of Romania.

Comparisons: Hungary's network is similar in size (international tax treaties of Hungary), while Estonia's smaller network matters for Romanian founders of Estonian companies (tax treaties of Estonia).

Common mistakes (and what they cost)

• Sending the residence certificate after the dividend was paid → 16% withheld instead of 5% or 0%, and a refund claim that takes months.
• Assuming foreign withholding settles the matter → Romanian residents still declare the income by 25 May; the undeclared difference attracts 0.08% daily penalties.
• Claiming a credit above the Romanian tax → ANAF disallows the excess; reclaim it from the source country instead.
• Treating a company treaty rate as yours → the 5% dividend rate usually needs a corporate shareholder with 10% or 25%; individuals get 10% or 15%.
• Ignoring the MLI principal purpose test → a holding company created only for the treaty rate is denied benefits and taxed at 16%.

Frequently asked questions

How many tax treaties does Romania have?

About 90 double tax conventions are in force, including all EU and EEA states, the UK, Switzerland, the US, Canada, Australia, China, Japan, India, the UAE and most of the Middle East and Central Asia. ANAF publishes the official list with the texts and protocols. Several older treaties date from the 1970s and have been updated by the Multilateral Instrument since 2022.

Does Romania have a tax treaty with the United States?

Yes, a convention signed in 1973 that remains in force. It caps US withholding on dividends paid to Romanian residents at 10% and Romania's withholding on dividends to US residents at 10%. Romanian residents claim the rate with form W-8BEN. Romania also has a FATCA intergovernmental agreement, so US account data flows to ANAF and vice versa.

What withholding tax applies if there is no treaty?

Romania's domestic rate of 16% on dividends, interest, royalties, commissions and services paid to non-residents. Payments to residents of jurisdictions on the EU non-cooperative list, where the transaction is artificial, are taxed at 50%. EU directives can still exempt dividends, interest and royalties between qualifying EU group companies even without a treaty.

How do I get a Romanian tax residence certificate?

Apply to your ANAF office, in person or through the online Virtual Private Space, with the standard request form and proof of residence. ANAF issues the certificate for a given year, usually within days. Foreign payers use it to apply treaty rates on your income; Romanian citizens living abroad use the foreign equivalent to prove they have left.

Does Romania use the exemption or credit method?

The credit method, in almost all treaties and in domestic law. Residents report worldwide income, compute Romanian tax at the normal rate and deduct foreign tax paid, limited to the Romanian tax on that income, country by country. A handful of older treaties exempt specific income with progression, but with a flat 10% rate progression has no effect.

Do tax treaties cover social security contributions in Romania?

No. Contributions follow EU Regulation 883/2004 within the EU, EEA and Switzerland, which assigns you to one system and uses A1 certificates, and bilateral agreements with countries such as Canada, Turkey, Israel and South Korea. For other countries, such as the US, you may owe contributions in both places unless one side exempts you under its own rules.

Related guides

• Tax residency in Romania
• How to obtain tax residency in Romania
• How to cease tax residency in Romania
• Corporate income taxes in Romania
• Capital gains tax in Romania
• Tax landscape overview of Romania
• International tax treaties of Hungary
• All country tax guides

Sources

• ANAF – National Agency for Fiscal Administration (treaty list and residence certificates)
• Ministry of Finance of Romania
• Legislative portal – Law 227/2015 on the Fiscal Code, Title VI
• National House of Public Pensions (CNPP) – A1 certificates and bilateral agreements
• OECD – Multilateral Instrument (MLI)
• European Commission – Taxation and Customs Union
• PwC Worldwide Tax Summaries – Romania

This guide is general information, not personalised tax advice. See how we research and review.