Tax Residency Rules for International Assignees and Remote Workers in Romania in 2026

An assignee working from a Bucharest apartment since February will cross 183 days in Romania sometime in August without any visa filing or calendar reminder telling them it happened. The threshold is a tax fact, not an immigration event, and by the time payroll or the individual notices, ANAF may already treat them as a Romanian tax resident liable on worldwide income from the date they arrived, not from day 184. Employers who assumed a temporary remote worker stayed outside Romanian tax law are often the ones left explaining a missed registration months later.

The same gap catches digital nomad visa holders. Romania's digital nomad framework, introduced by Law no. 22/2022 amending Government Emergency Ordinance no. 194/2002, governs who can legally reside and work remotely from Romania for a foreign employer or their own foreign-registered company, but it does not decide who pays Romanian tax and on what. That is a separate question under the Fiscal Code, and it applies to digital nomads exactly as it applies to any other foreign national present in the country. This article covers how Romanian tax residency is determined, what happens when someone is arguably resident in two countries at once, and what the individual and employer must each do once residency shifts.

How Romania Determines Tax Residency

Under the Romanian Fiscal Code, and per ANAF's published guidelines for establishing fiscal residence, a person is Romanian tax resident if any one of the following applies:

• They have their domicile in Romania
• Their center of vital interests is in Romania
• They are present in Romania for more than 183 days during any 12-consecutive-month period ending in the relevant calendar year
• They are a Romanian citizen employed abroad on behalf of the Romanian state

ANAF applies these in sequence, not as options to choose between: permanent home first, then center of vital interests if a home exists in more than one state, then the 183-day presence test if the first two do not resolve the question. Meeting any single condition triggers resident status.

The 183-day count runs across any rolling 12-consecutive-month period, not a calendar year, so days from late in one year can combine with days in the next to cross the threshold well before December 31. Once the 183rd day is reached, ANAF treats the individual as resident from their first day of presence in that window, not from day 184 onward, the detail most commonly missed by employees and payroll teams tracking travel days informally.

Where someone maintains a home in more than one country, Romania looks at where personal and economic ties are strongest: family location, schooling, employment, bank accounts, property, and business activity. An assignee whose spouse and children have relocated to Romania, with a local lease and bank account, builds a center-of-vital-interests case well before the day count matters.

Registering with ANAF and Obtaining a Tax ID

Notification to ANAF once someone becomes potentially tax resident is not automatic.

• A foreign individual expected to exceed 183 days must submit form Z015, the questionnaire for determining fiscal residence, within 30 days, with a passport copy, proof of Romanian address, and any foreign tax residency certificate held
• ANAF issues a determination, generally within 15 to 30 days
• Individuals departing Romania after being resident must file the mirror form, Z017, at least 30 days before departure
• Late or missing submissions carry fines and leave the tax position undocumented for any later audit

The individual also needs an identifier ANAF can attach a record to. Foreign nationals without a Romanian personal identification number (CNP) apply for a tax identification number, the NIF, using Form 030, within 30 days of first earning Romanian-source income, filed by the individual or, for non-residents taxed at source only, by the employer. Once immigration authorities issue a CNP, the taxpayer must ask ANAF to switch the record from NIF to CNP, as the two are not automatically linked.

Foreign Salary Income and Monthly Reporting

This is the part employers most often miss. When a Romanian tax resident continues to be paid by a foreign employer with no payroll presence in Romania, the withholding obligation falls on the individual, not the employer.

• Romanian-resident individuals earning salary from abroad while physically working in Romania must self-declare and pay a flat 10 percent income tax on it monthly, using Form 224, by the 25th of the following month
• This applies whether the person is a seconded assignee, a remote employee, or a digital nomad who has crossed into resident status
• An annual reconciliation return is also due by 25 May of the following year
• Where the employer maintains a Romanian payroll or entity, standard monthly withholding applies instead, shifting the burden back to the employer

ANAF updated Form 224's structure again in 2026, a sign this filing channel stays actively monitored.

Dual Tax Residency and Treaty Tie-Breakers

An assignee can meet Romania's residency criteria while still being tax resident in their home country under that country's own rules. Romania resolves this using the tie-breaker hierarchy in its double taxation treaties, most following the OECD Model Tax Convention's Article 4, applied in order until one test settles the question:

• Permanent home available to the individual
• Center of vital interests, where a home exists in both states
• Habitual abode, where vital interests cannot be placed in either state
• Nationality, where habitual abode is inconclusive
• Mutual agreement between the two tax authorities, as a last resort

Resolving dual residency in the individual's favor does not remove Romania's domestic filing obligations. A person confirmed as tax resident elsewhere under a treaty tie-breaker may still need to file ANAF's questionnaire and treaty documentation to formally establish that outcome.

Digital Nomads: A Separate Complication

Digital nomad visa holders are neither automatically exempt from Romanian tax residency nor automatically resident, the visa and the tax status sit under different laws. One who stays under 183 days in any 12-consecutive-month period, and does not otherwise establish a center of vital interests in Romania, can generally treat foreign-sourced income as outside Romanian tax scope. Cross the line, and the standard residency rules above apply in full, with the same NIF, Form 224, and annual filing consequences as any other foreign remote worker. The visa's own renewal conditions, requiring proof of qualifying income from Romanian tax authorities, make tracking the day count essential.

How Nestlers Group Supports Tax Residency Compliance

Nestlers Group's Tax Advisory team assesses residency exposure before relocation begins, modeling the 183-day count against travel and family relocation dates and identifying where a center-of-vital-interests argument could establish residency earlier than the day count alone suggests. Where dual residency is likely, the team prepares the treaty tie-breaker analysis alongside the Z015 or Z017 questionnaire ANAF expects.

Our Payroll and HR Compliance team manages the filing that follows a residency determination: the NIF through Form 030, the switch to a CNP once immigration status is confirmed, and the monthly Form 224 self-assessment for individuals still paid by a foreign entity. For employers running Romanian payroll for an assignee, the team folds the worldwide income position into standard monthly withholding.

The Relocation and Destination Services team tracks the residency signals HR teams rarely log, lease dates, school enrollment, family arrival dates, so the center-of-vital-interests position is documented as it happens, not reconstructed after ANAF asks for it.

Sources: Romanian Fiscal Code (Codul Fiscal); ANAF Guidelines for Fiscal Residence of Individuals (2023 edition); Law no. 22/2022 amending Government Emergency Ordinance no. 194/2002 (digital nomad framework); ANAF Form 224 instructions and 2026 update notices; OECD Model Tax Convention, Article 4 commentary on residence tie-breaker rules; PwC Worldwide Tax Summaries - Romania, Individual Residence and Tax Administration (2026)