Key challenges for the business environment in 2025: intensified tax audits and fis-cal policy changes

In the early months of this year, Romania’s business environment has faced two major challenges: an intensification of tax audits and the implementation of fiscal changes that directly affect the activity and budgets of taxpayers.

Tax inspections on the rise: who’s targeted and what are the implications

In 2025, the upward trend in tax audit activity continued, as observed in recent years, extending across all sectors (logistics, manufacturing, services and more) and targeting both legal entities and individuals. This is the assessment of experts from TPA Romania, a leading consultancy firm in Central and Eastern Europe, specialized in accounting, taxation, financial audit and legal advisory services.

According to the performance report issued by the National Agency for Fiscal Administration (NAFA), over 21,000 fiscal audits were conducted in 2024, representing a 2.8% increase compared to 2023. Approximately 75% of these audits targeted companies, while the remaining 25% focused on individuals. The additionally assessed tax liabilities amounted to RON 5.56 billion – nearly double the previous year’s figure – with 98% of the total having been imposed on companies. For individuals, the additional tax liabilities amounted to approximately RON 0.1 billion, similar to 2023.

“In parallel with the fiscal audits, NAFA has also intensified other control procedures, including unannounced controls, anti-fraud verifications, desk audits, personal tax situation reviews or fiscal risk analyses. Among these, desk audits (“verificarile documentare”) have become particularly frequent, now representing one of the most common forms of interaction between the tax authority and taxpayers,” explains Daniela Zar, Tax Partner at TPA Romania.

NAFA data shows over 29,000 desk audits were conducted in 2024, of which approximately 21,000 targeted companies and 8,000 targeted individuals. While the number of these checks rose by around 45% compared to 2023 (up from just over 20,000), the total amounts collected dropped by more than 15%, from RON 1.03 billion in 2023 to RON 850 million in 2024.

“Key sectors frequently targeted by the tax authorities include transport, trade and manufacturing – industries perceived as having a high fiscal risk. Recurring identified issues include unjustified VAT deductions, lack of supporting documentation for acquired services and price adjustments based on transfer pricing considerations,” adds Daniela Zar.

Digital tax compliance: SAF-T, e-Invoicing and their role in tax audits

The acceleration of digital interaction between taxpayers and NAFA is one of the key drivers behind the recent intensification of tax audits. This process gained significant momentum in 2024 and is expected to continue at pace in 2025: the SAF-T (D406) reporting requirement now applies to small taxpayers, the e-Invoicing system now covers B2C transactions, and the e-VAT framework adds a new layer of complexity to tax compliance. These tools provide tax authorities with rapid and centralized access to accounting and fiscal data, enabling automatic detection of inconsistencies and triggering targeted tax audits. In this new context, discrepancies or omissions in tax filings no longer go unnoticed, and taxpayers are often required to provide explanations and supporting documents, or can even be subjected to tax audits, the TPA Romania specialist explains.

“For companies, these obligations require additional investments in compatible IT systems, staff training, and, most importantly, a rigorous review of internal reporting procedures. Meeting digital compliance standards is essential not only for ensuring regulatory alignment, but also for minimizing the risk of tax audits. Periodic reviews of internal processes, adequate training for personnel involved in reporting, the use of accounting systems capable of generating accurate reports, and meticulous collection and archiving of supporting documentation are all strongly recommended. For many organizations, however, limited availability of financial and human resources remains a significant obstacle in fully adapting to these requirements,” notes Daniela Zar.

Taxation in 2025: what changed and who is affected

2025 brought a series of abrupt fiscal changes, including a revised tax regime for microenterprises, a higher dividend tax, the removal of tax incentives for certain categories of employees and the introduction of the so-called “pillar tax.”

One of the most debated changes, particularly affecting local entrepreneurs, is the reduction of the turnover threshold for microenterprises from EUR 500,000 to EUR 250,000 in 2025, with a further reduction to EUR 100,000 scheduled for January 2026. According to the TPA Romania expert, this change has forced many business to shift to the corporate income tax regime, a change that brings a more complex administrative burden and significantly increased tax and compliance costs.

In parallel, the dividend tax rate was increased from 8% to 10%, directly reducing the net return on investments.

Additionally, the IT, construction, agriculture and food industries have been affected by the removal of sector-specific tax incentives, resulting in significantly higher employment costs and reduced competitiveness.

At the same time, the construction tax (“pillar tax”) has been introduced. This tax amounts to 0.5% for constructions not subject to property tax, and 0.25% for state-owned constructions, and is levied on the net book value of constructions; however, several unclarities remain regarding its practical application.

Another important change concerns companies that are part of large groups with global revenues exceeding EUR 750 million. These businesses now face, for the first time, the complex calculations required under the legislation on minimum global taxation of large multinational and domestic groups (Law no. 431/2023). Specifically, the aim is to determine whether Romanian companies that are part of these groups are liable to pay an additional tax for the fiscal year 2024. If applicable, this tax will be due in addition to the standard corporate income tax. Notably, this additional tax is calculated based on individual and/or consolidated financial statements for 2024 and must be declared and paid by 30 June 2026.

According to TPA Romania specialist, all these changes compel businesses to revise their budgets, remuneration strategies and development plans. “SMEs at risk of exiting the microenterprise regime must evaluate whether they can absorb the additional cost of corporate income tax or need to scale down their activity, depending on their profit margins. Given the sudden nature of the changes, many affected businesses must now identify ways to finance the new tax burden – in particular since these were not anticipated when the current year’s budgets were prepared,” states Daniela Zar.

What lies ahead?

Romania is following the regional trend toward digitalization and tax base broadening but still stands out due to a higher level of legislative unpredictability, with fiscal changes often announced and implemented within very short timeframes.

“In the coming years, we expect the trend toward digitization and automation of tax processes to continue at an accelerated pace. NAFA will increasingly integrate data from various sources – tax filings, banking reports, customs declarations – into a centralized system designed to automatically identify high-risk taxpayers. As a result, tax audits will become more targeted, focusing on taxpayers with a high fiscal risk profile or on those who fail to comply voluntarily.

In the near future, after the formation of the new government, and amid growing budgetary pressures, we expect a new fiscal package to be released for public consultation. Although the measures are not yet known, an increase in fiscal pressure can be reasonably expected,” concludes Daniela Zar.