Romania: Obligatory Public Country-by-Country Reporting (CbCR) beginning in 2023

On 21 December 2021, a new EU Directive (“Directive (EU) 2021/2101”) entered into force. Under the Directive, companies are required to publish a so-called “report on income tax information” (“Public CbCR”). Romania was the first EU Member State to implement the directive into national law. Therefore, for financial years beginning on or after 1 January 2023, companies recorded in Romania are required to publish the Public CbCR.

The Public CbCR applies to multinational companies that are either domiciled in Romania or have a qualifying Romanian subsidiary or branch in Romania. In addition, consolidated revenues in the two previous financial years must exceed RON 3.7 billion (EUR 747 million). The Romanian implementation thus extends the scope of Directive 2021/2101 to all multinational groups with qualifying subsidiaries and branches in Romania, regardless of whether the ultimate parent company is located in the EU or not. The reporting obligations already start on 1 January 2023 and the first publication of a Public CbCR is to be made within 12 months of the balance sheet date of the first financial year the company is obliged to report.

The other EU Member States still have to observe the implementation deadline of June 2023. This means that the reporting obligation applies at the latest to financial years beginning on or after 22 June 2024.

Our transfer pricing experts provide you with a comprehensive CbCR analysis of your company and discuss with you whether and what impact the implementation of the Public CbCR in Romania will already have for the upcoming financial year. We will be happy to provide you with further support should your company actually be subject to the new reporting obligations.