Cross 183 Days and Romania Taxes You on Everything From the First Day You Arrived - and Keeps Taxing You for Three Years After You Leave for the Wrong Country
Answer
The general rule applies to you
No exception is recorded for citizens of Germany on this topic. That is the answer, not a gap - everything below is the rule you get, unchanged.
154 exceptions recorded across 56 countries · none match Germany to Romania · When you become a tax resident
Article 7 point 28 of the Fiscal Code makes an individual a Romanian tax resident on any one of four tests: domicile in Romania, the centre of vital interests in Romania, presence of more than 183 days in total in any 12 consecutive months ending in the calendar year concerned, or being a Romanian citizen working abroad for the Romanian state. The 183-day test is the one most people meet, and article 59(2^1) makes it retroactive: a non-resident who satisfies it is taxed on worldwide income from the first day of arrival in Romania, not from the day the threshold is crossed. The centre of vital interests test bites from the first day the person declares it. Leaving is harder than arriving. Article 59(5) and (7) keep a Romanian resident with domicile in Romania liable on worldwide income after a move: until the date of the change of residence where there is a double taxation treaty, and for the calendar year of the move plus the following three calendar years where there is not. In both cases a form has to be filed 30 days before departure. The one group the 183 days work for rather than against is digital nomads: the Fiscal Code exempts their foreign salary income and excuses them from the health contribution precisely while they stay under it.
At a glance
- Day-count test
- More than 183 days in total in any 12 consecutive months ending in the calendar year concerned
Article 7 point 28(c) of the Fiscal Code. It is a rolling window, not a calendar year.
- Other tests
- Domicile in Romania, or the centre of vital interests in Romania
Article 7 point 28(a) and (b) of the Fiscal Code. Any one of the four tests is enough.
- What the centre of vital interests means
- Where the person's personal and economic relations are closest
Article 7 point 6 of the Fiscal Code, which directs attention to the spouse and children among other things.
- When worldwide taxation starts
- From the first day of arrival in Romania
Article 59(2^1) of the Fiscal Code, for a person who satisfies the 183-day test. For the centre of vital interests test, article 59(2) starts it from the first day the person declares it.
- Treaty override
- Available on proof of residence elsewhere
Article 59(3) of the Fiscal Code excepts people who prove they are resident in a state with which Romania has a double taxation convention.
- Leaving for a treaty state
- Liable until the date of the change of residence
Article 59(5) of the Fiscal Code, with a form due 30 days before departure and proof of the new fiscal residence.
- Leaving for a non-treaty state
- Liable for the year of the move and the following 3 calendar years
Article 59(7) of the Fiscal Code.
- Digital nomads
- Foreign salary not taxable, and no health contribution, under 183 days
Article 227(1)(d) and article 153(1)(b) of the Fiscal Code, both on the same 183-day condition.
Requirements
- Count every day of presence across any 12 consecutive months, not per calendar year
- File the arrival questionnaire where you satisfy the centre of vital interests or 183-day test
- File the departure form 30 days before leaving Romania for more than 183 days
- Obtain a certificate of fiscal residence from the other state if you want a treaty to apply
Country-level policy
Romania publishes its law in Monitorul Oficial al României, Partea I, and that is the only text with legal force. Everything a reader can actually open is a consolidation, and Romanian consolidations are unusually honest about what they are. The consolidated text of Emergency Ordinance 194/2002 that the immigration authority itself publishes prints, above the first article, that the content of this act belongs exclusively to S.C. Centrul Teritorial de Calcul Electronic S.A. Piatra-Neamţ and is not a document of an official character, being intended for the information of users. It then prints something more useful still: a window. The copy read for these records states that it is valid from 27 April 2026 until 30 April 2026 - a four-day window that closed more than five months before it was read, because an amendment took effect on 1 May 2026 and this file was never replaced. The consolidation of Emergency Ordinance 102/2005 on the same site carries a window that closed on 14 March 2024. The tax administration says the same thing in its own words about the Fiscal Code: the text is updated by electronic means and is not a republication, and it names the last amending law rather than a date to which anything was swept. A Romanian text that looks current is making two separate claims, and the smaller print tells you which one has expired.
Romania wrote its digital nomad relief and its tax residence test around one number, and the two meet head-on. Article 227(1)(d) of the Fiscal Code makes a digital nomad's salary from a company registered outside Romania non-taxable, and article 153(1)(b) excepts the same person from the health insurance contribution - both on the express condition that they are present in Romania for periods not exceeding 183 days in any 12 consecutive months ending in the calendar year concerned. Article 7 point 28(c) of the same Code makes an individual a Romanian tax resident on presence exceeding 183 days in exactly the same window. So the digital nomad regime is built to stop at the line beyond which Romania taxes worldwide income. The immigration side does not stop there. Article 69(7) of Emergency Ordinance 194/2002 gives a digital nomad a first residence extension of six months and allows further extensions on the same conditions, so a person who renews once and stays is lawfully resident, has lost the exemption, has lost the exclusion from the health contribution, and under article 59(2^1) is taxed on worldwide income from the first day they arrived rather than from the day they crossed the threshold.
What applies to you
Nothing changes for a citizen of Germany
We have no rule recorded that treats your citizenship differently here, so the general rule above is the one that applies to you. That is an answer, not a gap.
What the law says
«28. persoană fizică rezidentă - orice persoană fizică ce îndeplinește cel puțin una dintre următoarele condiții: a) are domiciliul în România; b) centrul intereselor vitale ale persoanei este amplasat în România; c) este prezentă în România pentru o perioadă sau mai multe perioade care depășesc în total 183 de zile, pe parcursul oricărui interval de 12 luni consecutive, care se încheie în anul calendaristic vizat;»Our translation - not official
28. resident individual - any individual who meets at least one of the following conditions: a) has domicile in Romania; b) the person's centre of vital interests is located in Romania; c) is present in Romania for a period or periods exceeding in total 183 days during any interval of 12 consecutive months ending in the calendar year concerned;
Four tests, and the fourth is being a Romanian citizen working abroad as an official or employee of Romania in a foreign state.
Read it at the sourceAbout this source
Romania's tax administration. It publishes, on static.anaf.ro, an annotated edition of Law 227/2015 - the Fiscal Code - with the implementing methodological norms approved by Government Decision 1/2016 interleaved article by article, and names at the head of the page the last amending Act incorporated into each. The address has carried the year 2023 in its filename since that year and is updated in place, so the filename is not a version marker. It is the only reachable consolidated text of the Fiscal Code: the Ministry of Justice's legislative portal, which is the publisher of record for consolidations, answers nothing from outside Romania.
Standing: Applies the rule
Cannot be cited for: The page states what it is not: Textul este actualizat prin mijloace informatice şi nu reprezintă o republicare - the text is updated by electronic means and does not constitute a republication. It names the last amendment incorporated, not a date to which the text was swept, so it carries no consolidation cut-off in the sense this site records one, and no citation taken from it should be given a consolidatedAsOf. The official text is the Monitorul Oficial. It is authoritative about the Fiscal Code and about tax administration and about nothing else: immigration status, health insurance entitlement and social security coordination are decided by other instruments even where the Fiscal Code refers to them. The methodological norms printed beside each article are the Government's reading of the Code, not the Code, and the edition does not visually separate them in the text we extract.
We re-read it every 60 days. More about this source
«6. centrul intereselor vitale - locul de care relațiile personale și economice ale persoanei fizice sunt mai apropiate.»The definition the second test rests on. The same point continues that in analysing personal relations attention is to be paid to the family of the spouse and the children.
Read it at the sourceAbout this source
Romania's tax administration. It publishes, on static.anaf.ro, an annotated edition of Law 227/2015 - the Fiscal Code - with the implementing methodological norms approved by Government Decision 1/2016 interleaved article by article, and names at the head of the page the last amending Act incorporated into each. The address has carried the year 2023 in its filename since that year and is updated in place, so the filename is not a version marker. It is the only reachable consolidated text of the Fiscal Code: the Ministry of Justice's legislative portal, which is the publisher of record for consolidations, answers nothing from outside Romania.
Standing: Applies the rule
Cannot be cited for: The page states what it is not: Textul este actualizat prin mijloace informatice şi nu reprezintă o republicare - the text is updated by electronic means and does not constitute a republication. It names the last amendment incorporated, not a date to which the text was swept, so it carries no consolidation cut-off in the sense this site records one, and no citation taken from it should be given a consolidatedAsOf. The official text is the Monitorul Oficial. It is authoritative about the Fiscal Code and about tax administration and about nothing else: immigration status, health insurance entitlement and social security coordination are decided by other instruments even where the Fiscal Code refers to them. The methodological norms printed beside each article are the Government's reading of the Code, not the Code, and the edition does not visually separate them in the text we extract.
We re-read it every 60 days. More about this source
«(2 1 ) Persoana fizică nerezidentă care îndeplinește condiția de rezidență prevăzută la art. 7 pct. 28 lit. c) este supusă impozitului pe venit pentru veniturile obținute din orice sursă, atât din România, cât și din afara României, începând cu prima zi a sosirii în România.»Our translation - not official
A non-resident individual who meets the residence condition laid down in article 7 point 28(c) is subject to income tax on income obtained from any source, both from Romania and from outside Romania, starting from the first day of arrival in Romania.
The threshold is counted over twelve months but the liability reaches back to day one.
Read it at the sourceAbout this source
Romania's tax administration. It publishes, on static.anaf.ro, an annotated edition of Law 227/2015 - the Fiscal Code - with the implementing methodological norms approved by Government Decision 1/2016 interleaved article by article, and names at the head of the page the last amending Act incorporated into each. The address has carried the year 2023 in its filename since that year and is updated in place, so the filename is not a version marker. It is the only reachable consolidated text of the Fiscal Code: the Ministry of Justice's legislative portal, which is the publisher of record for consolidations, answers nothing from outside Romania.
Standing: Applies the rule
Cannot be cited for: The page states what it is not: Textul este actualizat prin mijloace informatice şi nu reprezintă o republicare - the text is updated by electronic means and does not constitute a republication. It names the last amendment incorporated, not a date to which the text was swept, so it carries no consolidation cut-off in the sense this site records one, and no citation taken from it should be given a consolidatedAsOf. The official text is the Monitorul Oficial. It is authoritative about the Fiscal Code and about tax administration and about nothing else: immigration status, health insurance entitlement and social security coordination are decided by other instruments even where the Fiscal Code refers to them. The methodological norms printed beside each article are the Government's reading of the Code, not the Code, and the edition does not visually separate them in the text we extract.
We re-read it every 60 days. More about this source
«(7) Persoana fizică rezidentă română, cu domiciliul în România, care dovedește schimbarea rezidenței într-un stat cu care România nu are încheiată convenție de evitare a dublei impuneri este obligată în continuare la plata impozitului pe veniturile obținute din orice sursă, atât din România, cât și din afara României, pentru anul calendaristic în care are loc schimbarea rezidenței, precum și în următorii 3 ani calendaristici.»The three-year tail after a move to a state with no double taxation convention, with the departure form due 30 days before leaving.
Read it at the sourceAbout this source
Romania's tax administration. It publishes, on static.anaf.ro, an annotated edition of Law 227/2015 - the Fiscal Code - with the implementing methodological norms approved by Government Decision 1/2016 interleaved article by article, and names at the head of the page the last amending Act incorporated into each. The address has carried the year 2023 in its filename since that year and is updated in place, so the filename is not a version marker. It is the only reachable consolidated text of the Fiscal Code: the Ministry of Justice's legislative portal, which is the publisher of record for consolidations, answers nothing from outside Romania.
Standing: Applies the rule
Cannot be cited for: The page states what it is not: Textul este actualizat prin mijloace informatice şi nu reprezintă o republicare - the text is updated by electronic means and does not constitute a republication. It names the last amendment incorporated, not a date to which the text was swept, so it carries no consolidation cut-off in the sense this site records one, and no citation taken from it should be given a consolidatedAsOf. The official text is the Monitorul Oficial. It is authoritative about the Fiscal Code and about tax administration and about nothing else: immigration status, health insurance entitlement and social security coordination are decided by other instruments even where the Fiscal Code refers to them. The methodological norms printed beside each article are the Government's reading of the Code, not the Code, and the edition does not visually separate them in the text we extract.
We re-read it every 60 days. More about this source
«d) veniturile din salarii sau asimilate salariilor obținute de persoana fizică cu statut de nomad digital, definit potrivit prevederilor Ordonanței de urgență a Guvernului nr. 194/2002, republicată, cu modificările și completările ulterioare, din activitatea pe care o prestează în baza unui contract de muncă la o companie înregistrată în afara României și care prestează servicii prin utilizarea tehnologiei informației și comunicațiilor sau care deține o companie înregistrată în afara României, în cadrul căreia prestează servicii prin utilizarea tehnologiei informației și comunicațiilor și poate desfășura activitatea de angajat sau activitatea din cadrul companiei, de la distanță, prin utilizarea tehnologiei informației și comunicațiilor, în condițiile în care persoana fizică este prezentă pe teritoriul României pentru o perioadă sau mai multe perioade care nu depășesc 183 de zile pe parcursul oricărui interval de 12 luni consecutive, care se încheie în anul calendaristic vizat.»The digital nomad exemption, which depends on staying the right side of the same 183 days.
Read it at the sourceAbout this source
Romania's tax administration. It publishes, on static.anaf.ro, an annotated edition of Law 227/2015 - the Fiscal Code - with the implementing methodological norms approved by Government Decision 1/2016 interleaved article by article, and names at the head of the page the last amending Act incorporated into each. The address has carried the year 2023 in its filename since that year and is updated in place, so the filename is not a version marker. It is the only reachable consolidated text of the Fiscal Code: the Ministry of Justice's legislative portal, which is the publisher of record for consolidations, answers nothing from outside Romania.
Standing: Applies the rule
Cannot be cited for: The page states what it is not: Textul este actualizat prin mijloace informatice şi nu reprezintă o republicare - the text is updated by electronic means and does not constitute a republication. It names the last amendment incorporated, not a date to which the text was swept, so it carries no consolidation cut-off in the sense this site records one, and no citation taken from it should be given a consolidatedAsOf. The official text is the Monitorul Oficial. It is authoritative about the Fiscal Code and about tax administration and about nothing else: immigration status, health insurance entitlement and social security coordination are decided by other instruments even where the Fiscal Code refers to them. The methodological norms printed beside each article are the Government's reading of the Code, not the Code, and the edition does not visually separate them in the text we extract.
We re-read it every 60 days. More about this source
«b) cetățenii străini și apatrizii care au solicitat și au obținut prelungirea dreptului de ședere temporară ori au domiciliul în România, cu excepția nomazilor digitali, definiți în conformitate cu prevederile art. 2 lit. n 4 ) din Ordonanța de urgență a Guvernului nr. 194/2002, republicată, cu modificările și completările ulterioare, în condițiile în care nomadul digital este prezent pe teritoriul României pentru o perioadă sau mai multe perioade care nu depășesc 183 de zile pe parcursul oricărui interval de 12 luni consecutive, care se încheie în anul calendaristic vizat;»Foreigners who obtained an extension of temporary residence are health insurance contributors, except digital nomads under 183 days.
Read it at the sourceAbout this source
Romania's tax administration. It publishes, on static.anaf.ro, an annotated edition of Law 227/2015 - the Fiscal Code - with the implementing methodological norms approved by Government Decision 1/2016 interleaved article by article, and names at the head of the page the last amending Act incorporated into each. The address has carried the year 2023 in its filename since that year and is updated in place, so the filename is not a version marker. It is the only reachable consolidated text of the Fiscal Code: the Ministry of Justice's legislative portal, which is the publisher of record for consolidations, answers nothing from outside Romania.
Standing: Applies the rule
Cannot be cited for: The page states what it is not: Textul este actualizat prin mijloace informatice şi nu reprezintă o republicare - the text is updated by electronic means and does not constitute a republication. It names the last amendment incorporated, not a date to which the text was swept, so it carries no consolidation cut-off in the sense this site records one, and no citation taken from it should be given a consolidatedAsOf. The official text is the Monitorul Oficial. It is authoritative about the Fiscal Code and about tax administration and about nothing else: immigration status, health insurance entitlement and social security coordination are decided by other instruments even where the Fiscal Code refers to them. The methodological norms printed beside each article are the Government's reading of the Code, not the Code, and the edition does not visually separate them in the text we extract.
We re-read it every 60 days. More about this source
Practical notes
The publisher says what this text is and is not. The tax administration's edition carries the line Textul este actualizat prin mijloace informatice şi nu reprezintă o republicare - the text is updated by electronic means and is not a republication - and names the last amendment incorporated rather than a date to which it has been swept. That is why no consolidation cut-off is recorded on these citations: naming the last amending law is not the same claim as naming a date up to which the text was checked.
Nothing here is a rate. The Fiscal Code's income tax rates, the health and pension contributions and the treatment of particular kinds of income were not read for this record, which is about when Romania starts taxing a person rather than how much.
The 183-day test and the digital nomad exemption are the same number read from opposite sides, and they are in different titles of the same Code. A nomad who renews a six-month permit twice crosses both lines at once.
- administersLegea nr. 227/2015 privind Codul fiscal, ediţie adnotată
Agenţia Naţională de Administrare Fiscală
About this source
Romania's tax administration. It publishes, on static.anaf.ro, an annotated edition of Law 227/2015 - the Fiscal Code - with the implementing methodological norms approved by Government Decision 1/2016 interleaved article by article, and names at the head of the page the last amending Act incorporated into each. The address has carried the year 2023 in its filename since that year and is updated in place, so the filename is not a version marker. It is the only reachable consolidated text of the Fiscal Code: the Ministry of Justice's legislative portal, which is the publisher of record for consolidations, answers nothing from outside Romania.
Standing: Applies the rule
Cannot be cited for: The page states what it is not: Textul este actualizat prin mijloace informatice şi nu reprezintă o republicare - the text is updated by electronic means and does not constitute a republication. It names the last amendment incorporated, not a date to which the text was swept, so it carries no consolidation cut-off in the sense this site records one, and no citation taken from it should be given a consolidatedAsOf. The official text is the Monitorul Oficial. It is authoritative about the Fiscal Code and about tax administration and about nothing else: immigration status, health insurance entitlement and social security coordination are decided by other instruments even where the Fiscal Code refers to them. The methodological norms printed beside each article are the Government's reading of the Code, not the Code, and the edition does not visually separate them in the text we extract.
We re-read it every 60 days. More about this source