Romania: Pillar Two Optional Designation Notification (Form N408) Now Available
12 Aug 2025
In brief
The National Agency for Fiscal Administration (ANAF) published yesterday, 11 August 2025, the official smart PDF form (N408) enabling the designation of a single Romanian Constituent Entity within a Pillar Two group to declare and pay the Qualified Domestic Minimum Top-up Tax (QDMTT) on behalf of all its Romanian Constituent Entities.
In detail
The Romanian Pillar Two legislation (Law no. 431/2023) provides for an election mechanism in cases where there are multiple Romanian Constituent Entities (CE) in a Pillar Two group. Specifically, there is an annual option to designate one CE for declaring and paying the QDMTT (if any) on behalf of all Romanian CE. This mechanism is optional and, if no option is made, each Romanian entity must declare and pay separately its portion of QDMTT. Moreover, if there is only one Romanian CE within a Pillar Two Group, the designation is not needed.
According to Law no. 431/2023, the above option must be exercised within six months following the last day of the relevant financial reporting period.
On 9 July 2025, the Romanian Tax Authorities issued Order no. 1729/2025, detailing this Pillar Two designation procedure. Although the Order required electronic submission via a smart PDF form, the form itself was not published at that time.
This smart PDF form became available on ANAF’s website only yesterday, 11 August 2025 (it can be accessed here).
The form should be submitted electronically via www.e-guvernare.ro by any Romanian CE’s representative directly or through an empowered person.
N408 includes key information, such as the Pillar Two group name, information on all Romanian constituent entities, details of the designated entity, contact information, and fiscal reporting periods.
Our team is available for more information on this topic and its implications for you, or for assistance with the above-mentioned designation procedure/smart PDF form.
In order to be up-to-date with the latest information about Tax and Legal changes, you can subscribe to our Newsletter:
Contact us
