According to an update from the OECD, Romania deposited on 6 March 2023 the notification confirming the completion of its internal procedures for the entry into effect of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) for 55 of its covered agreement (tax treaties). The notification confirming the completion of internal procedures is required because Romania has taken the reservation that for the MLI to become effective, Romania must first deposit such a notification.

With the deposit of the notification, the provisions of the MLI will generally apply for the 55 notified covered agreements, for Romania:

• with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2024; and
• with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 January 2024.

For the other countries, the provisions of the MLI generally apply from 1 January 2024 for withholding taxes and 5 October 2023 for other taxes or, in certain cases, 1 January 2024.

The 55 covered agreements include Romania's tax treaties with Albania, Australia, Austria, Belgium, Bosnia and Herzegovina, Bulgaria, Canada, China, Croatia, Cyprus, Czech Republic, Denmark, Egypt, Estonia, Finland, France, Georgia, Greece, Hong Kong, Hungary, Iceland, India, Indonesia, Ireland, Israel, Japan, Jordan, Kazakhstan, Korea (Republic of), Latvia, Lithuania, Luxembourg, Malaysia, Malta, Netherlands, Norway, Pakistan, Poland, Portugal, Qatar, Russia, San Marino, Saudi Arabia, Serbia (Yugoslavia), Singapore, Slovak Republic, Slovenia, South Africa, Spain, Sweden, Thailand, Ukraine, United Arab Emirates, United Kingdom, and Uruguay.