3% Tax Bonus for 2025: Romania’s Tax Authority Grants It Automatically, No Application Needed

Companies that filed all their returns and settled their 2025 tax on time receive a bonus of 3% of it without having to ask for anything. Not as money in the bank account, but as an amount that offsets other tax obligations. Through Order No. 987/2026, the Ministry of Finance approved the procedure for granting the 3% bonus on the annual corporate income tax and on the microenterprise income tax due for tax year 2025, or for the modified tax year that begins in 2025. The benefit itself had already been granted by Article 7 of Government Emergency Ordinance No. 8/2026, the economic relaunch package published in the Official Gazette of Romania, Part I, No. 147 of 25 February 2026, alongside the other tax measures of this year. What was missing until now was precisely the administrative mechanism through which the money reaches the taxpayer.

The order was signed on 3 August 2026 and published on 17 August 2026, in the Official Gazette of Romania No. 678. Article 7 paragraph (10) of the ordinance gave the Minister of Finance a deadline of no more than 45 days from the entry into force of the ordinance, that is, a deadline that fell in April 2026. The procedure arrived roughly four months past that deadline, and by then the statutory filing deadlines for the returns to which the order ties the moment of issuing the decisions had already expired as well.

The scope is drawn broadly. The procedure applies to corporate income tax payers regardless of the declaration and payment system laid down in Article 41 of the Tax Code, and to payers of microenterprise income tax under Title III of the same law. It also covers the mixed situation of microenterprises that became corporate income tax payers during 2025, in which case the rate applies to both taxes.

What it changes in practice

The first effect is that the bonus is established ex officio. The taxpayer analytical records unit identifies the taxpayers concerned in the tax records, draws up separate lists by category, generated automatically from the IT system, and prepares one decision for each of them. The taxpayer files no application and submits no additional documents.

The second effect is the timetable, which has no fixed date in the order. The decisions are issued after the statutory deadline for filing the annual corporate income tax return for 2025 has expired, in the case of corporate income tax payers, and after the deadline for filing the return for the fourth quarter of tax year 2025 has expired, in the case of microenterprises. The order sets no calendar date of its own for issuing the decisions.

The third effect concerns the three cumulative conditions. The taxpayer must have filed all returns in line with the tax vector (the taxpayer’s registered tax obligations), must have settled in full and by the statutory deadlines the annual corporate income tax or the microenterprise income tax due for 2025, and must record no other overdue tax obligation or overdue budgetary claims individualised in enforcement titles, as at the statutory deadline for filing those returns.

The fourth effect is the calculation method, set out across four situations. The 3% rate applies to the annual corporate income tax, from which the amounts redirected under the law are deducted, to the tax due for the whole year by a microenterprise, determined by adding up the quarterly taxes, to both taxes in the case of microenterprises that became corporate income tax payers in 2025, and to the corporate income tax at the level of the minimum turnover tax, where this is owed at the end of the year under Article 18¹ of the Tax Code. For a tax group, the base is the tax declared by the responsible legal entity.

The fifth effect, the most important one in practice, is that the money does not come back into the bank account. The amounts covered by the bonus are not refunded, they are used for offsetting against the taxpayer’s tax obligations, under Article 167 of the Tax Procedure Code. There is a single exception: obligations for which the statute of limitations on the right to request a refund is reached are actually refunded, provided they have not been offset in the meantime against other budgetary obligations.

The sixth effect is the one that can take the bonus back. If, after the decision has been issued, the taxpayer files an amended return or receives, following a tax audit, a tax assessment decision with an additional tax obligation of more than 3%, the bonus granted initially is cancelled in full. It is also cancelled if the amended return shows that no tax obligation is recorded any longer. If the correction goes the other way, reducing the obligation, the bonus does not disappear, it is recalculated downwards through a new decision.

The seventh effect is that the decision can be challenged. The forms approved by the order, reproduced in Annexes 2 to 4 to the official gazette issue attached above, state the remedy expressly: an administrative appeal under Articles 268 and 269 of the Tax Procedure Code, within the period laid down in Article 270, on pain of forfeiture, filed with the issuing tax authority. The decision takes effect from the date of communication, under Article 47 of the same code.

What has changed compared with the previous situation

The right to the bonus had existed since February 2026, but it could not be put into practice. Article 7 of Government Emergency Ordinance No. 8/2026 established the benefit, the general conditions and the offsetting rule, yet it left the application to a procedure that was to be approved by order of the Minister of Finance, on a proposal from the President of ANAF, the National Agency for Fiscal Administration. Order No. 987/2026 is that procedure.

The order also brings several clarifications that were not found in the ordinance. The one most favourable to the taxpayer concerns the first condition: the requirement to have filed all returns in line with the tax vector is considered met even where, for the periods in which no returns were filed, the tax obligations were established by a decision of the tax authority. In the ordinance the condition was worded plainly, without this nuance.

The second clarification concerns what it means to be in arrears. The order refers expressly to Article 157 of the Tax Procedure Code for the definition of an overdue budgetary obligation and adds, compared with the text of the ordinance, the reference to overdue budgetary claims individualised in enforcement titles issued under the law and held in the records of the central tax authority for recovery.

The third difference is one of placement. The ordinance dealt with corporate income tax at the level of the minimum turnover tax in a separate paragraph, which extended the application of the article to that situation. The order brings it directly into the list of calculation bases in the procedure, alongside the other three.

Finally, the order creates the instruments that were missing: three form templates, for granting, amending and cancelling the bonus, plus the obligation to archive the lists electronically in the tax records. The operation of adding the overpayment is carried out on the schedule for adding or deducting tax obligations, the template in Annex No. 8 to Order of the President of ANAF No. 63/2017.

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