Romania Gazettes Ordinance Amending Pillar 2 Global Minimum Tax Law

The Romanian Official Gazette Aug. 29 published Ordinance No. 21, amending Law No. 431/2023 on the global minimum taxation of multinational enterprise (MNE) groups and large domestic groups under OECD Pillar Two. The ordinance includes measures: 1) including qualified refundable tax credits and tradable transferable tax credits in income when computing a constituent entity’s qualified profit or loss; 2) amending the national additional tax calculation; 3) allowing expenses with a negative value of additional taxes to be carried forward, subject to conditions; 4) allowing filing constituent entities with effective tax rates (ETRs) that meet the safe harbor and penalty relief ...