The Romanian Government has introduced Government Emergency Ordinance (GEO) no. 21/2025, officially published in Official Gazette no. 300 on April 4, 2025.
The new ordinance builds on the foundation of GEO 156/2024, which set a uniform annual tax of 1 percent on constructions. GEO no. 21/2025 replaces this approach with a more targeted taxation system, featuring reduced and differentiated rates. They are the following:
- 0.5% tax rate: This applies to the net value of constructions that meet the following criteria:
- They are excluded from the standard local building tax.
- They form part of the taxpayer’s assets as of December 31 of the preceding year.
- 0.25% tax rate: This applies to constructions that:
- Belong to the public or private domains of state or local authorities.
- Are used, managed, leased or held free of charge by the taxpayer under a legal agreement. In this case, the taxpayer responsible for administration, concession, leasing or free use assumes the tax liability.
Note: This tax only applies to constructions situated within Romania’s territorial land area. Constructions in the maritime zone are exempt.
Early payment incentive: Taxpayers who settle their dues by May 25 of the respective year will be eligible for a 10 percent tax discount.
Takeaway: The revised provisions reflect a more precise approach to taxing special constructions, ensuring alignment with legal and economic realities.
By Bogdan Papandopol, Partner, and Luiza Onofrei, Senior Associate, Dentons