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5.5. Source Rules with Respect to Income Derived by Non-Residents


Dividends received from companies that are incorporated and registered in Romania and from foreign companies authorized to operate in Romania are deemed Romanian sourced.


Interest paid by Romanian  residents to non-residents is deemed Romanian  sourced.


Royalty fees paid for the use of intellectual property in Romania, is deemed Romanian  sourced.

Rental income

Rental income from property situated in Romania is deemed Romanian  sourced.

Service fees

Service fees paid to a non-resident are deemed Romanian  sourced if the payer is a resident, regardless of where the services are actually performed.