Volodymyr wrote to us a month ago. Registered as FOP in Ukraine, Group 3, 5% single tax, working remotely as an IT consultant, turnover around €4,000 per month. He arrived in Romania from Odessa under temporary protection and has been living in Cluj-Napoca for 220 days. He has no Romanian bank account, only a rental agreement for the apartment. In Ukraine he pays his taxes properly. The question he asked me: "So I do not pay tax in Romania, right? And if I do, how much and how? Friends in Poland pay only a 5-10% difference, what about me here?" The answer is longer. If you are in a similar situation (Ukrainian FOP, temporary protection in Romania, over 183 days), this article is for you.
The 183-day rule: when you become a Romanian tax resident
Codul fiscal (Article 7, point 28) defines you as a Romanian tax resident if you have domiciliu in Romania, your center of vital interests is in Romania, or you were physically present in Romania for more than 183 days in any 12 consecutive months.
Volodymyr crossed the 183-day mark roughly at month 7 of his stay. By the letter of the law, he became a Romanian tax resident from that moment.
Within 30 days after day 183, you are required to file with ANAF the Chestionar pentru stabilirea rezidenței fiscale a persoanei fizice la sosirea în România, form Z015. ANAF does not actively chase people under temporary protection, but you still have a window to get things in order without penalties.
Z015: how to file
Chestionar Z015 is not an income tax return. It is a form on which you describe your situation. Based on Z015, ANAF issues a Decizie privind rezidența fiscală.
Filing methods:
Through SPV on anaf.ro. For Ukrainians with a CNP this works.
In person at the local ANAF Registratura, or via a notarized power of attorney.
By post with return receipt.
ANAF usually issues the Decizie within 30-60 days after filing.
Declarația Unică 212: what you declare as a resident
If ANAF recognizes you as a Romanian tax resident, you are required to file annually the Declarația Unică (Form 212).
It covers:
Income from Romania
Income from abroad, including your Ukrainian FOP income
Ukraine-Romania treaty: fiscal credit
The two countries have a Double Taxation Avoidance Agreement since 1996. Romania applies fiscal credit: the tax paid in Ukraine is deducted from the Romanian tax.
But the Ukrainian FOP single tax does not formally qualify as an income tax under the treaty. ANAF has the right not to credit it in full.
€4,000/month income | Romanian rules |
|---|---|
10% impozit pe venit | €400/mo |
25% CAS | €200/mo |
10% CASS | €80/mo |
Total | ~€680/mo |
In Ukraine you pay ~€250/mo. If you become a Romanian resident: an extra €400-500/mo on top of the Ukrainian tax.
That is not the "5-10% difference" as in Poland. Poland applies a different method.
2026 deadlines and the 3% bonus
25 May 2026: standard filing and payment deadline for 2025 income.
15 April 2026: if you file and pay in full by this date, you get a 3% bonus on impozit pe venit. Savings on €4,000/mo income roughly €150-170 for the year.
New for 2026: ANAF makes available in SPV a pre-filled version of Form 212. For foreign income, you add the data yourself.
Myths vs. reality
"I am just a refugee." Temporary protection is a migration status, not a tax status. 183 days triggers residency regardless.
"I have no Romanian bank account." True today, not a guarantee. Property purchase, SRL, status change can wake up the process.
"The treaty protects me." Partially: from double taxation yes, but not from filing obligations and not from CAS/CASS.
"In Poland they only pay the difference." Different methods, direct comparison does not work.
What to do in practice
Path 1: Do nothing (risk)
Fits if you plan to leave Romania. Retroactive risk grows.
Path 2: File Z015 now + DU 212
You file the chestionar with the current date. Pro: full legalization. Con: tax burden goes from ~5% to ~17-20%.
Path 3: Register a micro SRL in Romania
You register a microîntreprindere (1% on turnover up to €250,000).
For IT at €4,000/mo (€48,000/year):
1% impozit pe venit: €480/year
Administrator salary + payroll taxes: ~€3,700/year
Dividends on 80% of turnover: 10% × €38,400 = €3,840/year
Total: ~€8,000/year (~17% effective).
Numerically similar to Path 2, but gives access to property, credit, EU funding.
Concrete steps for Volodymyr
Consultation with a consultant fiscal (€100-200)
File Z015 via SPV
Receive the Decizie (30-60 days)
Decide between Path 2 and Path 3
If Path 3: register the SRL via ONRC (€300-500, 5-10 days)
File Declarația Unică 212 by 15 April 2026 (3% bonus) or by 25 May 2026
What not to do
Do not file Z015 backdated by a year. Creates retroactive obligations.
Do not register assets under relatives. Tax avoidance at first audit.
Do not trust "pay cash" at property purchase. The notary reports.
Do not ignore ANAF letters. Silence is read as avoidance.
Sources
At Fintaxy we work daily with Ukrainian, Belarusian, Russian and Moldovan freelancers and sole traders living in Romania. We speak Russian, Ukrainian, Romanian and English. Write at fintaxy.com.
This article is for informational purposes only and does not constitute individual tax advice. Consult a licensed consultant fiscal or a CECCAR-certified accountant for your specific case.