Updated on 20 October 2026
The special constructions tax (impozitul pe construcții), colloquially known in Romania as „taxa pe stâlp”, was reintroduced from 2025 and is due only once more, for 2026. From 2027, Title X of the Romanian Fiscal Code is repealed. Below we explain who pays, how much, by when, and what should be checked before the tax ceases to apply.
What the special constructions tax is and who is liable for it
„Taxa pe stâlp” is the colloquial Romanian name for the special constructions tax (impozitul pe construcții), governed by Title X of the Fiscal Code (Articles 496–500). The tax previously applied between 2014 and 2016, at a rate of 1.5%, and was abolished from 2017.
The tax is payable by Romanian legal entities, by foreign legal entities carrying on business through a permanent establishment in Romania and by other entities provided for by law, in respect of constructions located in Romania. It mainly concerns constructions in group 1 of the Catalogue on the classification and normal useful lives of fixed assets, such as networks, poles, pipelines, internal roads or industrial structures. Accordingly, the tax liability must be determined in compliance with the categories of taxpayers, the exemptions and the rules on taxable constructions laid down in Title X of the Fiscal Code, as applicable to the financial year for which the tax is calculated.
The tax does not apply to constructions for which building tax is due under Title IX of the Fiscal Code, nor to those exempt from building tax.
How much is the special constructions tax in 2026
- 0.5% of the net book value of the constructions held by the taxpayer on 31 December 2025, i.e. the value recorded in the construction accounts less accumulated accounting depreciation;
- 0.25% of the value of constructions in the public or private domain of the State or of administrative-territorial units which the taxpayer holds under administration, concession, free use or lease.
The value is determined only once, on 31 December of the preceding year, and is not recalculated during the year. The special constructions tax is a deductible expense in determining taxable profit.
Filing and payment deadlines in 2026
- 25 May 2026 – calculation and filing of the tax return;
- 30 June 2026 – payment of the first instalment (50%);
- 31 October 2026 – payment of the second instalment (50%).
Taxpayers who file and pay the tax in full by 25 May 2026 receive a 10% discount. For taxpayers with a modified financial year, the deadlines are tied to the fifth, sixth and tenth months of the financial year.
Paying the final instalment by 31 October 2026? We review the calculation and the return before you pay.
What changes from 2027
Under GEO no. 89/2025, Title X – Tax on constructions is repealed from 2027 or, as the case may be, from the modified financial year beginning in 2027. Accordingly, 2026 is the last year for which the tax is calculated, declared and paid.
The repeal does not extinguish the obligations for 2025 and 2026. Returns and payments for those years remain subject to tax audit within the general five-year limitation period in tax matters, and any differences may be assessed by the National Agency for Fiscal Administration (ANAF) even after 2027.
Legal issues raised by the special constructions tax
The reintroduction of the tax has raised concerns about the predictability of tax legislation. Under Article 4(1) of the Fiscal Code, tax amendments should enter into force at least six months after publication. GEO no. 156/2024, however, was adopted at the end of 2024 and applied from 1 January 2025, and the rules were amended again only a few months later, by GEO no. 21/2025.
These rapid changes have created practical difficulties, particularly in determining the tax base: which constructions fall within group 1, how to treat constructions on which building tax is already paid and how to determine net book value.
What companies should check
- The tax base for 2026. Which constructions were included, whether any of them already attract building tax and whether the net book value on 31 December 2025 has been correctly determined.
- The 2025 returns. Whether the reduced rate introduced by GEO no. 21/2025 was correctly applied and whether amended returns are required.
- Sumele plătite în plus. Eventualele diferențe pot fi recuperate prin cerere de restituire sau compensare, în condițiile prevăzute de Titlul VII – Capitolul II din Codul de procedură fiscală în termenul general de prescripție fiscală de 5 ani prevăzut de art. 219 din Codul de procedură fiscală.
- ANAF audits. The documentation supporting the classification of constructions should be retained, as the returns for 2025 and 2026 may be audited even after the tax is repealed.
Have you paid special constructions tax on structures that did not fall within the taxable base? We assess whether you can recover the amounts.
Frequently asked questions about the special constructions tax
Is the special constructions tax still payable in 2027?
No. Under GEO no. 89/2025, the tax on constructions is repealed from 2027. The last year for which it is due is 2026.
What is the special constructions tax rate in 2026?
0.5% of the net book value of the constructions on 31 December 2025, and 0.25% for constructions of the State or of administrative-territorial units used by the taxpayer.
By when must the special constructions tax be declared and paid?
The return must be filed by 25 May 2026, and payment made in two equal instalments, by 30 June and 31 October 2026. Payment in full by 25 May earns a 10% discount.
Is the special constructions tax deductible?
Yes. The special constructions tax is a deductible expense in calculating corporate income tax.
Does the special constructions tax also apply to buildings?
No, if building tax is due on the building in question under Title IX of the Fiscal Code. The special constructions tax mainly concerns the special constructions in group 1 of the Catalogue of fixed assets.
How we can help
The Adesman & Asociații team assists companies with the determination and filing of taxes, in tax audits and in challenging tax assessment decisions. Find out more about our tax law practice.
Do you have a question about the special constructions tax?
This material is provided for general information only and does not constitute legal advice. For an analysis of your company's specific situation, please contact us.
