December 31, 2025 – Deadline for Country-by-Country Reporting (CbCR) for Multinational Enterprise (MNE) Groups

CbCR: A Priority for Multinational Enterprise Groups

With the December 31, 2025 deadline approaching, compliance with Country-by-Country Reporting (CbCR) is a priority for multinational enterprise (MNE) groups, especially since failure to meet CbCR requirements may result in fines of up to €20,000 and increase tax risk, including the possibility of additional tax audits.

To support these companies, Romanian Tax Authorities recently conducted an awareness campaign, emphasizing the importance and necessity of CbCR compliance for MNEs, thus encouraging Romanian companies to take appropriate action.

Public CbCR reporting requires multinational groups, both with headquarters in the EU and outside the EU, with a consolidated annual turnover exceeding €750 million, to disclose information regarding corporate income tax, aiming to reduce tax evasion and increase global tax transparency.

Although Romania is a signatory to the CbC MCAA, the lack of functional mechanisms and bilateral agreements with certain non-EU jurisdictions requires Romanian companies, in cases where reporting has not been performed by another entity within the EU group, to submit additional reports that would not normally be necessary.

Ultimate parent companies of MNE groups resident in Romania, as well as MNE group entities from non-EU jurisdictions, remain required to report via Form R404 and the corresponding XML schema, except in cases where the CbCR report has already been submitted in another EU jurisdiction, as regulated by Government Emergency Ordinance 42/2017.

Conclusion

Given the time pressure and the potentially large volume of data to be processed, Romanian companies should take prompt action to prepare the information required for reporting in order to meet the December 31, 2025 deadline.

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