Plățile intragrup sub incidența STTR – clauza de supunere la impozitare
Intragroup Payments Subject to the STTR – Tax Compliance Clause

Summary/Abstract: Romania completes the fiscal legislative framework by introducing a new instrument aimed at multinational groups. By Law no. 60/2026, Romania ratifies the Multilateral Convention to facilitate the implementation of Pillar II of the Taxability Rule (‘STTR MLI’ – Subject To Tax Rule via Multilateral Instrument) developed at the level of the Organization for Economic Cooperation and Development (OECD), which allows for the taxation of payments at source intra-group, when they reach jurisdictions where they are taxed below 9%. The new law does not replace the global minimum tax regime of 15%, provided for by Directive (EU) 2022/2523 and transposed in Romania by Law no. 431/2023, but applies together with it. If Law no. 431/2023 concerns minimum taxation at group level, Law no. 60/2026 applies only to certain transactions between affiliated companies.

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