Romania Digital Services Tax: Cross-Border Impact Analysis

Romania's Ministry of Finance has published draft legislation introducing a 3% digital services tax (DST) on revenues generated from digital services provided to Romanian users. The tax applies to companies with global revenues exceeding EUR 750 million and Romanian digital service revenues exceeding EUR 5 million annually.

For Three Seas technology trade, the implications extend beyond direct tax liability. The DST creates compliance complexity for cross-border digital service delivery, particularly for companies operating across multiple Three Seas jurisdictions with varying digital taxation frameworks. Our analysis identifies 47 technology companies in the EEIT network that would be directly affected.

The ARCS Framework compliance module has been updated to include DST impact modeling, enabling affected companies to assess their exposure and develop mitigation strategies. Key considerations include revenue attribution methodology, permanent establishment implications, and interaction with existing bilateral tax treaties.