Creditul fiscal pentru activitățile de cercetare-dezvoltare: recalibrarea facilităților fiscale în era impozitului minim global
Tax Credit for Research and Development Activities: Recalibrating Tax Incentives in the Era of the Global Minimum Tax

Summary/Abstract: The introduction of the Pillar Two rules ensuring a global minimum level of taxation has resulted in the additional deduction for research and development (R&D) expenses becoming inapplicable for certain taxpayers subject to this global minimum tax. In this context, the adoption of a refundable tax credit amounting to 10% of eligible R&D expenses, with the possibility to carry forward and obtain a refund of the incentive, eliminates the tax inequity arising from the implementation of the Pillar Two rules. As a result, tax incentives related to R&D activities are once again relevant for taxpayers liable to the global minimum tax. This mechanism aligns Romania with similar international practices, restores tax equity, and provides a strategic tool to support investments in innovation, including in the IT sector, which remains significantly affected by the elimination of the income tax exemption on programmers’ salaries.

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