Romania’s Ministry of Finance has released a draft administrative form to support the implementation of its domestic Pillar Two legislation. The form enables multinational enterprise (MNE) groups operating in Romania to designate a single local entity responsible for filing and paying the Qualified Domestic Minimum Top-up Tax (QDMTT).
Published on June 20, 2025, the draft form outlines the required information and filing procedure. It is a step toward aligning Romania’s tax system with the OECD’s Global Anti-Base Erosion (GloBE) rules under Pillar Two, as adopted in the EU Minimum Tax Directive (Council Directive (EU) 2022/2523).
Legal Basis and Applicability
The draft form is based on Article 48(10) of Romania’s minimum tax legislation. When multiple constituent entities from the same MNE group operate in Romania, the law permits the group to nominate one of them to manage the QDMTT obligations.
This nomination must be made by submitting the official form to the Romanian tax authority within six months after the end of the relevant fiscal year. Failure to comply may result in each local entity being independently liable for the minimum tax calculation and reporting.
Required Information on the Draft Form
To complete the form, the following information must be provided:
1. Reporting Entity Identification
- Legal name and Romanian Tax Identification Number (TIN).
- Indication of whether the reporting entity is the Ultimate Parent Entity (UPE) or another group member.
- Confirmation that the entity agrees to assume QDMTT responsibilities.
2. Group Information
- Legal name of the MNE group as reflected in its consolidated financial statements.
- Fiscal year to which the designation applies.
- Whether this is the group’s first year subject to the Romanian minimum tax rules.
3. List of Other Romanian Constituent Entities
- Names, registered addresses, and TINs of all other group members operating in Romania.
- Statement confirming that these entities consent to the nomination of the designated filer.
4. Contact Details
- Name, position, and contact information of the authorized representative for the nominated entity.
The form is intended for electronic submission via the Romanian tax administration’s online portal. Final formatting instructions and electronic filing requirements will be released when the order is finalized.
Strategic Considerations for MNE Groups
The introduction of this filing mechanism carries several implications:
- Simplified Administration: Centralizing responsibility for QDMTT filings helps reduce compliance complexity and improves internal oversight.
- Data Coordination: Accurate form completion requires cooperation among all Romanian entities within the group to collect and verify data.
- Compliance Timeline: The six-month deadline from year-end imposes pressure on internal tax and finance teams to act promptly—especially for groups with a calendar-year reporting cycle.
- Documentation Requirements: Formal authorization or internal agreements may be needed to confirm mutual consent among local group members.
Next Steps for Affected Entities
Although the draft form is not yet in force, MNE groups should take the following preparatory actions:
- Monitor updates from Romania’s Ministry of Finance for the final version of the form and related instructions.
- Review internal structures to determine which Romanian entity is best positioned to act as the reporting party.
- Begin collecting information across all Romanian constituent entities in anticipation of the reporting obligation.
- Assess internal systems for GloBE data readiness and filing capabilities.
Conclusion
Romania’s publication of a draft form for nominating a Pillar Two reporting entity demonstrates its ongoing commitment to implementing the global minimum tax framework. The form offers clarity and structure for multinational groups seeking to streamline their compliance obligations. Tax professionals and in-house finance teams are encouraged to begin preparing early to ensure timely and accurate submissions once the rules are finalized.
For companies with complex organizational footprints in Romania, this is also an opportunity to evaluate the need for technology solutions or specialist advisory support to manage Pillar Two compliance more efficiently.
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