Beneficial owners - Romania


The following types of beneficial owner are recognised for tax purposes in Romania:

  • Residents of Double Taxation Treaties (DTT) countries;

The following types of beneficial owner are not eligible for relief:

  • Romanian residents

Residents of DTT countries

Relief at source is available to beneficial owners that:

  • Qualify for a reduced rate of withholding tax in accordance with a DTT between their country of residence and Romania; and
  • Meet the conditions laid down by the applicable DTT to obtain the reduced withholding tax rate.

The maximum rate of withholding tax is defined in the relevant DTT.

Beneficial owners (of equities) not eligible for relief at source

The following beneficial owners cannot apply for a reduced rate at source through Clearstream Banking:

  • Legal entities, resident and non-resident, entitled to exemption based on domestic law provisions;
  • Resident individuals.

Reclaim of withholding tax directly from the Romanian tax authorities may be possible. Please consult a tax advisor for further information.