Inheritance Tax Exemption Until September and the TollRo Charge from 31 August: What Law No. 170/2026 Changes

Law No. 170/2026 gathers a series of fiscal-budgetary measures without a single theme: from an inheritance-tax exemption for successions finalised by autumn, to new rules for companies in preventive insolvency, emergency financing for public enterprises with money frozen in international disputes and, most visibly for truck drivers, the STRR/TollRo electronic road toll taking effect on 31 August 2026. The law, promulgated and published in the Official Gazette of Romania on the same day, 5 August 2026, adds to the series of 2026 fiscal-budgetary acts, alongside the earlier measures on the reduced VAT rate for first homes.

For individuals, the most concrete change concerns inheritance: successions settled and finalised by 30 September 2026 inclusive are exempt from the tax on transferring property through inheritance, if the legal 2-year deadline from the date of death falls between 14 July and 30 September 2026. In practice, heirs who risked exceeding the 2-year window (after which inheritance tax generally becomes due) get a temporary exemption, provided they finalise the succession proceedings by 30 September.

For businesses issuing VAT-exempt invoices to exempt persons (diplomats, international institutions, other categories under the Tax Code), the law clarifies what happens when the exemption certificate arrives late: if the supplier obtains the certificate after delivery but within the limitation period, the exemption applies retroactively from the date of the chargeable event; if the certificate is missing during a tax inspection, the tax authorities collect the VAT, with regularisation to follow once the certificate appears.

The broadest technical component concerns debtors in insolvency-prevention procedures (preventive concordat, ad-hoc mandate): the law sets a clear order for extinguishing tax debts, allows VAT to be offset against obligations outside the restructuring agreement, and bans including in the restructuring agreement the debts on which an already-obtained payment schedule depends, to avoid a vicious circle between the two debtor-protection mechanisms.

On infrastructure, the law brings new rules for Exim Banca Românească, which is mandated to grant temporary, interest-free financing to public enterprises whose accounts have been frozen through enforced execution for state debts arising from international disputes, so their activity isn’t halted. A similar state-budget cover mechanism is provided for ROMATSA, if EUROCONTROL withholds amounts owed to it for the same reasons.

What it changes in practice

For heirs close to the expiry of the 2-year deadline, the temporary inheritance-tax exemption can mean direct savings, but only if the succession is actually finalised by 30 September 2026, a tight deadline for more complicated cases.

For freight road carriers, from 31 August 2026 a new charge appears, TollRo, applied to vehicles over 3.5 tonnes MTMA used on the SETRE network, collected through the new electronic STRR system, which replaces the old road-toll mechanisms for commercial transport. Mixed-transport vehicles are treated, for this purpose, as freight vehicles.

The charge now has the equipment that checks whether it was paid: 300 control sites with 1,258 cameras, for the rovinieță and TollRo, worth 132 million lei including VAT.

For companies in preventive insolvency, the new tax rules should reduce administrative bottlenecks between ANAF and the courts approving restructuring plans, the main benefit being clarity on the payment order and the ability to use VAT refunds to extinguish debts, not just accumulate them.

What has changed compared with the previous situation

• A new, temporary inheritance-tax exemption window: successions finalised by 30 September 2026, with the 2-year deadline falling between 14 July and 30 September 2026, no longer owe tax.
• Clarified VAT regularisation: the Tax Procedure Code gets explicit rules for late-obtained exemption certificates.
• A dedicated extinguishment order for preventive insolvency: the Tax Procedure Code introduces, for the first time at this level of detail, a special order for paying tax debts for companies in preventive concordat or ad-hoc mandate.
• A new road charge for trucks: the STRR system and the TollRo charge, applicable from 31 August 2026, replace the old commercial road-toll rules under Law No. 226/2023.
• A new emergency-financing mechanism: Exim Banca Românească can temporarily finance, interest-free, public enterprises with accounts frozen over state debts from international disputes.

Advantages and disadvantages

Practical advice

Frequently asked questions