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Updated Special Construction Tax Rules: Key points for 2025

Romania
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The Romanian Government has introduced Government Emergency Ordinance (GEO) no. 21/2025, officially published in Official Gazette no. 300 on April 4, 2025.

The new ordinance builds on the foundation of GEO 156/2024, which set a uniform annual tax of 1 percent on constructions. GEO no. 21/2025 replaces this approach with a more targeted taxation system, featuring reduced and differentiated rates. They are the following:

  • 0.5% tax rate: This applies to the net value of constructions that meet the following criteria:
    • They are excluded from the standard local building tax.
    • They form part of the taxpayer’s assets as of December 31 of the preceding year.
  • 0.25% tax rate: This applies to constructions that:
    • Belong to the public or private domains of state or local authorities.
    • Are used, managed, leased or held free of charge by the taxpayer under a legal agreement. In this case, the taxpayer responsible for administration, concession, leasing or free use assumes the tax liability.

Note: This tax only applies to constructions situated within Romania’s territorial land area. Constructions in the maritime zone are exempt.

Early payment incentive: Taxpayers who settle their dues by May 25 of the respective year will be eligible for a 10 percent tax discount.

Takeaway: The revised provisions reflect a more precise approach to taxing special constructions, ensuring alignment with legal and economic realities.

By Bogdan Papandopol, Partner, and Luiza Onofrei, Senior Associate, Dentons

Romanian Knowledge Partner

Țuca Zbârcea & Asociații is a full-service independent law firm, employing cross-disciplinary teams of lawyers, insolvency practitioners, tax consultants, IP counsellors, economists and staff members. It also operates a secondary law office in Cluj-Napoca (Romania), and has a ‘best-friend’ agreement with a leading law firm in the Republic of Moldova. In addition, thanks to the firm’s dedicated Foreign Desks, the team provides the full range of services to international investors seeking to gain a foothold or expand their existing operations in Romania. Since 2019, the firm and its tax arm are collaborating with Andersen Global in Romania.

Țuca Zbârcea & Asociaţii is providing legal services in every aspect of business, covering all major areas of practice: corporate and M&A; litigation and international arbitration; corporate tax; public procurement; TMT; employment; insurance; banking and finance; capital markets; competition; healthcare and pharmaceutical; energy and natural resources; environmental; intellectual property; real estate; regulatory legal services.

Țuca Zbârcea & Asociaţii is a First-Tier law firm in all international legal directories and a multiple award-winning law firm both locally and internationally. It received the CEE Deal of the Year Award (DOTY Awards 2021) and the Law Firm of the Year Award: Romania (IFLR Europe Awards 2021). 

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