On June 20, 2025, Romania issued a draft order requiring multinational groups to designate a single reporting entity for QDMTT (Domestic Minimum Top-Up Tax) purposes.
Context and scope
Article 48(10) of Romania’s Minimum Tax Law provides that where several entities of the same group operate locally, they may designate a single entity responsible for reporting and paying the QDMTT tax. This form allows that choice to be made within six months of the end of the tax period.
Form requirements
The draft specifies that the following must be included, among other things:
- Identification of the notifying entity (UPE, designated local entity, or other).
- Name of the multinational group as it appears in the consolidated financial statements.
- Accurate details of the Romanian entities involved: name, address, tax identification number, and official designation of the person who will file and pay QDMTT.
- Tax period covered by the notification, indicating whether it is the first year of reporting.
- Contact information of the reporting entity.
This information must reflect the status as of the last day of the fiscal year.
Benefits and next steps
With the introduction of this form, Romania:
- Provides operational clarity to groups with multiple local entities.
- Facilitates coordinated compliance with the QDMTT.
- Establishes a formal mechanism for the voluntary selection of the responsible entity.
The form will remain open for public consultation, and comments are expected to be adopted before it enters into force.
Source: OECDPillars