The Pillar 2 rules in Romania, the forms to be filed with ANAF, the practical steps and the documents to prepare for QDMTT and GIR.
Pillar 2 rules were introduced in Romania by Law No. 431/2023 and generally apply to multinational groups and large domestic groups for financial periods beginning on or after 31 December 2023. Their purpose is to ensure a minimum effective tax rate of 15%, and in Romania the shortfall can be collected through the national top up tax, i.e., QDMTT.
Who is affected?
Pillar 2 primarily targets groups that fall within the scope of the global minimum tax rules and that have entities in Romania. For these groups, local obligations go beyond a tax calculation and include reporting, notifications to ANAF and maintaining documentation to support the reported figures.
Obligations in Romania
There are three main compliance areas in Romania: notification of the entity designated for QDMTT, filing or notifying the GIR, and, if there is additional tax payable, declaring and paying that tax. To designate a single Romanian entity to declare and pay QDMTT on behalf of all Romanian entities, the N408 form is used, published by ANAF under Order No. 1729/2025. Separately, ANAF approved forms for GIR and for notifying the GIR filing obligation under Order No. 218/2026.
If the parent is in the EU
If the GIR return is filed in another EU Member State, the constituent entities in Romania do not file the full GIR locally but only notify the GIR to the Romanian tax authority. This rule matters for groups with a parent company in France, Germany or another EU state because automatic information exchange occurs between Member States. Conversely, if the GIR is not filed in another EU Member State under the required conditions, reporting may become necessary in Romania as well.
Practical steps to follow
- Verify that the group falls within the Pillar 2 scope and clearly identify the Romanian entities included in the reporting perimeter.
- Choose, if applicable, a designated Romanian entity to manage the obligation to declare and pay the national top up tax for all local entities.
- Assess whether the group must file the GIR locally or only the GIR notification, depending on where the group level return is filed.
Documents to prepare
For form N408, ANAF requires information about the taxpayer submitting the notification, the group name used in consolidated financial statements, the list of constituent entities in Romania, the indication of the designated entity and the fiscal period concerned. In practice, the internal file should also include the group chart, identification data of the Romanian entities, the internal designation decision, the applicable fiscal year and documents supporting the top up tax calculation. It is important to have linkage documents between core financial data and the adjustments used in the calculation, as well as a clear record of internal processes and controls.
How to fill the forms
The N408 form published by ANAF must be submitted electronically and signed with a qualified electronic certificate. The same applies to the forms related to GIR and the GIR notification.
Key deadlines
For groups with a calendar fiscal year, the optional notification to designate the constituent entity via form N408 had a deadline of 31 December 2025 for the 2024 year, and for subsequent years the general rule is 6 months from the last day of the relevant financial year. Regarding GIR at EU level, the first effective reporting by Romanian authorities under the new DAC9 framework is scheduled no earlier than 1 December 2026, for the first financial year beginning after 31 December 2023. 2026 is the year by which groups should already have internal processes, data and responsibilities defined.
