Tax residence in Romania for Pakistani taxpayers

Romania treats you as resident if you have a domicile there, if your centre of vital interests is in Romania, or if you are present there for more than 183 days in any 12 consecutive months ending in the calendar year — any one test is enough. Pakistan counts its own tax year of 1 July – 30 June, and a Pakistani citizen can stay resident under s. 82(d) with fewer than 183 days. Where both countries claim you, Art. 4(2) of the 1999 Pakistan–Romania Convention decides: permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement. Both countries relieve double tax by credit (Art. 24).

Check your status: Pakistan and Romania

Free, no sign-up, about 3 minutes. Conclusion under Pakistan's Income Tax Ordinance, 2001, compared with the law of Romania and the tax treaty.

When Romania treats you as a tax resident

The first criterion of the Fiscal Code is a domicile in Romania — the address declared as the main home and recorded in the Romanian identity card. It is a formal criterion: you keep it while living abroad until you officially establish your domicile abroad.

Even without a domicile in Romania you are resident if the centre of your vital interests — family, work, business, assets — is in Romania.

The threshold is checked over any 12 consecutive months ending in the year concerned, not only the calendar year; you must exceed 183 days (184 or more).

Romanian citizens working abroad as officials or employees of the Romanian State are resident regardless of the days spent abroad.

You have a domicile in Romania — you are a Romanian tax resident (art. 7 pct. 28(a) of the Fiscal Code) and owe tax on income from all sources, in Romania and abroad. If you have moved to a State with which Romania has a treaty, you remain resident until the date your residence changes, which you prove with the departure questionnaire and a certificate of residence from the other State (art. 59(5)).
The centre of your vital interests is in Romania — you are a Romanian tax resident (art. 7 pct. 28(b) of the Fiscal Code) and owe tax on income from all sources. The conclusion depends on ANAF's overall assessment of your personal and economic relations.
You were present in Romania for more than 183 days in a 12-month interval ending in this year — you are a Romanian tax resident (art. 7 pct. 28(c) of the Fiscal Code), taxed on income from all sources from the first day of arrival (art. 59(2^1)). If a State with which Romania has a treaty also treats you as resident, dual residence is settled under the treaty (art. 1(3)), and residence in the other State is proven with a certificate of tax residence (art. 59(6)).
You are a Romanian citizen working abroad as an official or employee of the Romanian State — you are a Romanian tax resident (art. 7 pct. 28(d) of the Fiscal Code), whatever the number of days spent abroad.

When you are a nonresident

You have no domicile in Romania, your centre of vital interests is not there and you did not exceed 183 days in 12 months — you are a non-resident. Romania taxes only your income from Romania (for example pay for work done in Romania, rent from property in Romania).
Formally you meet no residence criterion, but it is not clear where the centre of your vital interests is. ANAF may consider that it is in Romania — then you would be resident. Keep evidence of your family, home, work and assets in the other country.

Where the rules of Romania clash with Pakistani tax rules

Collision: a Romanian domicile keeps you resident in Romania. Romania treats you as resident as long as your domicile — the address recorded in your Romanian identity card — is in Romania, even if you live and work in Pakistan; it ends only when you officially establish your domicile abroad (a Romanian passport stating a domicile abroad) or prove a change of residence with the departure questionnaire and a certificate of residence from Pakistan (art. 59(5) of the Fiscal Code). If Pakistan also treats you as resident, Art. 4(2) of the Pakistan–Romania Convention (1999) decides: permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement.
Collision: centre of vital interests in Romania. Without a Romanian domicile and with fewer than 183 days, closer personal and economic ties with Romania (family, a Romanian employer, business, real estate, bank accounts) still make you resident in Romania (art. 7 pct. 6 and pct. 28(b) of the Fiscal Code); ANAF assesses them as a whole, giving priority to personal ties. If Pakistan also treats you as resident, Art. 4(2) of the treaty decides; where you have a permanent home in both countries, the centre of vital interests is the next test.
Collision: more than 183 days in Romania in any 12 months. More than 183 days in Romania in any 12 consecutive months ending in the year make you resident in Romania from the first day of arrival (art. 7 pct. 28(c), art. 59(2^1) of the Fiscal Code). Because the window is rolling and the Pakistan tax year runs on different dates, you can at the same time be resident in Pakistan — typically in the year you move. A permanent home available only in Pakistan still makes you a resident of Pakistan under Art. 4(2) of the treaty; Romania can then tax only Romanian-source income, such as pay for work in Romania beyond the limits of the employment article. Within 30 days after reaching 183 days of presence, file the arrival questionnaire with ANAF (OMFP 1099/2016).
Collision: Pakistani citizen resident in both countries. Since tax year 2023, s. 82(d) of the Income Tax Ordinance treats a Pakistani citizen as resident in Pakistan unless he or she was present in one other country for more than 182 days in the Pakistani tax year and is a resident taxpayer there. Romania can treat you as resident through a domicile, the centre of vital interests or more than 183 days in a 12-month window that need not match the 1 July – 30 June year. If both apply, Art. 4(2) of the Convention decides: permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement. Keep a Romanian certificate of tax residence and a day count for both periods.

What else to know

Which treaty applies: the Pakistan–Romania Convention (1999). The Pakistan–Romania Convention signed at Bucharest on 27 July 1999 (in force 13 January 2001; effect in Pakistan from the tax year beginning 1 July 2002, in Romania from 1 January 2002) replaced the 1978 Convention. Residence tie-breaker: Art. 4(2) — permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement; employment: Art. 16 (183 days in any 12-month period from first arrival); private pensions: Art. 19 — State of residence only; relief: Art. 24 — credit; MAP: Art. 26 (2 years).
Different counting periods: a rolling 12 months in Romania. Pakistan counts days in its tax year (1 July – 30 June); Romania treats you as resident with more than 183 days in Romania in any 12 consecutive months ending in the calendar year, counting the days of arrival and departure, or with a domicile or the centre of vital interests in Romania whatever the days. The treaty's 183-day employment test (Art. 16(2)(a)) is different again: any 12-month period beginning with your first arrival in the other State. Keep a day count for each of these periods.
How Pakistan and Romania relieve double taxation. Both countries use the credit method (Art. 24). If you are resident in Pakistan, Romanian tax on Romanian-source income is credited against Pakistani tax on that income, separately for each head of income, with no carry-forward (s. 103); salary for work in Romania on which Romanian tax was withheld and paid is exempt in Pakistan (s. 102). If you are resident in Romania, Romania credits the Pakistani tax up to the Romanian tax on that income, per country and type of income (art. 131 of the Fiscal Code); foreign income is declared in the Romanian single return by 25 May of the following year.
Working in Romania while resident in Pakistan. Pay for work physically done in Romania is Romanian-source income. If Pakistan is your treaty residence, Romania does not tax it only if all three conditions of Art. 16(2) are met: not more than 183 days in Romania in any 12-month period beginning with your first arrival; an employer that is not resident in Romania; and pay not borne by a Romanian permanent establishment or fixed base. Otherwise the Romanian payer withholds 10% income tax (plus social contributions under Romanian rules) on the pay for Romanian work days; in Pakistan that salary is exempt under s. 102 if the Romanian tax was withheld and paid.
Certificates of residence and treaty rates in Romania. To benefit from the treaty in Romania — for example a reduced withholding rate on Romanian dividends, interest or royalties — give the Romanian payer a certificate of tax residence issued by the Pakistan tax authority; it is valid for the year(s) for which it is issued, and the Romanian rate may not exceed the treaty rate (arts 59(6) and 230(1) of the Fiscal Code). If you are resident in Romania, ANAF issues a Romanian certificate of tax residence on request (OMFP 1099/2016, art. 13(3)).
Year of the move: Romania can split the year. A person without a Romanian domicile becomes resident in Romania from the day of arrival (183-day test) or from the declared date the centre of vital interests moves, and remains resident until departure (art. 59(2), (2^1) and (4) of the Fiscal Code); a person with a Romanian domicile remains resident until the date the change of residence is proven (art. 59(5)). Pakistan decides your status for its whole tax year. Where both countries treat you as resident for the same period, the treaty decides for that period.
Romanian State official posted abroad. A Romanian citizen working abroad as an official or employee of the Romanian State is resident in Romania whatever the days spent abroad (art. 7 pct. 28(d) of the Fiscal Code). If Pakistan also treats you as resident, check the government service article of the treaty for salaries paid by the Romanian State and the treaty's tie-breaker.
Social security: no Pakistan–Romania agreement. Pakistan is not on the CNPP list of countries with which Romania has bilateral social security agreements, and EU Regulation 883/2004 does not apply to Pakistan. Work in Romania is generally subject to Romanian social contributions (CAS 25%, CASS 10% for employees) under Romanian rules, with no certificate of coverage based on Pakistani coverage.

How dual residence is resolved

If both countries treat you as a resident, Art. 4(2) of the treaty applies: Convention between the Government of the Islamic Republic of Pakistan and the Government of Romania for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income — signed at Bucharest on 27 July 1999. The tests are applied in order — permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement between the tax authorities.

Terms you will come across in Romania

domiciliu: domicile — the main home recorded in the Romanian identity card; resident under art. 7 pct. 28(a) of the Fiscal Code whatever the days
centrul intereselor vitale: centre of vital interests — family, a Romanian employer, business, property and bank accounts, with priority for personal ties
chestionarul la sosire: arrival questionnaire, filed with ANAF within 30 days after 183 days of presence are reached (OMFP 1099/2016)
Declarația unică: the single return for income tax and social contributions, filed by 25 May of the following year
certificat de rezidență fiscală: certificate of tax residence; a Pakistani one lets a Romanian payer apply the treaty rate
CAS / CASS: Romanian pension contribution (25%) and health contribution (10%) withheld from salaries

Questions

Which tax treaty applies between Pakistan and Romania?

The Convention signed at Bucharest on 27 July 1999, in force since 13 January 2001, which replaced the 1978 Convention; it applies in Pakistan from the tax year beginning 1 July 2002. Its tie-breaker for individuals is Art. 4(2), and a mutual agreement case must be presented within two years (Art. 26).

I work in Romania for a few months. Does Romania tax my salary?

If you are resident in Pakistan under the treaty, Romania does not tax it only if you are present no more than 183 days in any 12-month period beginning with your first arrival, your employer is not Romanian-resident and no Romanian permanent establishment or fixed base bears the pay (Art. 16(2)). Otherwise the Romanian payer withholds 10% income tax; Pakistan exempts foreign salary on which that tax was withheld and paid (s. 102).

Is there a Pakistan–Romania social security agreement?

No. Pakistan is not on the CNPP list of Romania's bilateral social security agreements, and EU Regulation 883/2004 does not apply to Pakistan. Work in Romania is generally subject to Romanian contributions (CAS 25%, CASS 10% for employees).

Sources

Legislation and official guidance

art. 7 pct. 28 of the Fiscal Code (Codul fiscal, Law No. 227/2015) — A resident individual is any person who meets at least one of these conditions: (a) has a domicile in Romania; (b) the centre of vital interests is located in Romania; (c) is present in Romania for one or more periods exceeding in total 183 days in any interval of 12 consecutive months ending in the calendar year concerned; (d) is a Romanian citizen working abroad as an official or employee of Romania in a foreign State.
arts 87 and 91 of the Civil Code (Law No. 287/2009) — An individual's domicile is where he or she declares the main home to be (art. 87); domicile and residence are proven by the entries in the identity card (art. 91(1)). The residence is the place of the secondary home (art. 88).
art. 34 of Law No. 248/2005 on the free movement of Romanian citizens abroad — A Romanian citizen who has established a domicile abroad may request an ordinary passport stating the State of domicile; on return to Romania the mention of the domicile abroad is cancelled (art. 36).
art. 7 pct. 6 of the Fiscal Code — The centre of vital interests is the place with which a person's personal and economic relations are closer. Personal relations: the family (spouse, children, dependants), membership of charitable or religious organisations, cultural activities. Economic relations: employment with a Romanian employer, business activity in Romania, real estate and bank accounts in Romania, etc.
ANAF — Cluj Regional Directorate, information note on the tax residence of individuals (18.06.2026) — Residence exists if at least one of the four conditions is met; the centre of vital interests is assessed as a whole, with priority for personal relations; the 183-day threshold is checked over any rolling 12-month interval ending in the year concerned, the days of arrival and departure usually being counted.
art. 59(2), (2^1) and (3) of the Fiscal Code — A non-resident who becomes resident through the centre of vital interests (art. 7 pct. 28(b)) owes tax on income from all sources from the first day on which he or she declares that it is in Romania (para. 2); one who becomes resident by exceeding 183 days (point (c)) — from the first day of arrival in Romania (para. 2^1). Para. 3: persons who prove that they are residents of a State with which Romania has an applicable double tax treaty are excepted from para. 2.
art. 59(1) of the Fiscal Code — Income tax applies to: Romanian residents with a domicile in Romania — on income from any source, in and outside Romania; other residents — on income from any source from the date they become resident; non-residents — only on income from Romania (permanent establishment, dependent activity in Romania, other income from Romania).
art. 59(5) of the Fiscal Code — A Romanian resident with a domicile in Romania who proves a change of residence to a State with which Romania has a double tax treaty continues to owe tax on income from all sources until the date of the change; he or she files the departure questionnaire 30 days in advance and proves tax residence in the other State.
art. 1(3) of the Fiscal Code — Where a provision of the Fiscal Code conflicts with a provision of a treaty to which Romania is a party, the treaty provision applies.
art. 59(6) of the Fiscal Code — Residents of States with which Romania has treaties prove their tax residence with a certificate of residence issued by the competent tax authority of the foreign State (or another authority empowered to certify residence); the certificate is valid for the year(s) for which it is issued.
Order of the Minister of Public Finance No. 1099/2016 (Official Gazette No. 577 of 29.07.2016) — Approves the arrival questionnaire (annex 1), the departure questionnaire (annex 2) and ANAF's notifications (annexes 3 and 4). Arrival questionnaire: within 30 days after 183 days of presence are reached (art. 14); departure: 30 days in advance (art. 19); ANAF answers within 30 and 15 days respectively. Order of criteria for dual residence: domicile/permanent home, centre of vital interests, habitual abode, nationality, mutual agreement procedure (art. 9), with the OECD Commentary on Article 4 (art. 10). Certificate of residence on request (art. 13(3)).
art. 7 pct. 27 of the Fiscal Code — A non-resident individual is one who does not meet the conditions of point 28, as well as a foreign citizen with diplomatic or consular status in Romania, a foreign official or employee of an international body registered in Romania or of a foreign State in Romania, and their family members.
Art. 4(2) Pakistan–Romania Convention (1999) — Individual resident of both States: (a) resident of the State in which he has a permanent home available to him; if he has a permanent home in both States, of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the centre of vital interests cannot be determined, or if he has no permanent home in either State, of the State in which he has an habitual abode; (c) habitual abode in both or in neither — the State of which he is a national; (d) national of both or of neither — the competent authorities settle the question by mutual agreement.
Income Tax Ordinance, 2001, s. 107(2) — Subject to s. 109, a double taxation agreement and its implementing notification have effect notwithstanding anything in any other law, so far as they provide relief from tax under the Ordinance, determine the Pakistan-source income of non-residents, or provide for exchange of information.
Income Tax Ordinance, 2001, s. 82(a) — An individual is a resident individual for a tax year if present in Pakistan for a period of, or periods amounting in aggregate to, 183 days or more in the tax year (1 July – 30 June).
Art. 16(2) Pakistan–Romania Convention (1999) — Remuneration of a resident of one State for employment exercised in the other State is taxable only in the first State if (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any 12-month period beginning with the date of his first arrival in that State, (b) it is paid by, or on behalf of, an employer who is not a resident of the other State, and (c) it is not borne by a permanent establishment or fixed base which the employer has in the other State.
Income Tax Ordinance, 2001, s. 82(d) (inserted by the Finance Act, 2022; consolidated text amended up to 30.06.2026 listed by FBR) — A citizen of Pakistan is also a resident individual if he or she is not present in any other country for more than 182 days during the tax year, or is not a resident taxpayer of any other country. Applies from tax year 2023.
Art. 24 Pakistan–Romania Convention (1999) — The State of residence allows as a deduction from the income tax of its resident an amount equal to the income tax paid in the other State; the deduction shall not exceed that part of the tax, as computed before the deduction, which is attributable to the income which may be taxed in the other State.
Income Tax Ordinance, 2001, s. 103 — A resident taxpayer gets a credit for foreign income tax on foreign-source income equal to the lesser of the foreign tax paid and the Pakistan tax on that income (average Pakistani rate × net foreign-source income), computed separately for each head of income; unused credit is not refunded, carried back or forward; the foreign tax must be paid within two years after the end of the tax year.
art. 131 of the Fiscal Code — The foreign tax credit or exemption is granted if the treaty concluded by Romania with the State where the tax was paid applies, the tax was actually paid (proof: a document of the foreign authority or the payer) and the income falls within a category of art. 61. The credit may not exceed the Romanian tax on the foreign income and is computed per country and per type of income; foreign currency is converted at the annual average rate of the National Bank of Romania. Income exempt under a treaty is declared in the single return.
Income Tax Ordinance, 2001, s. 102 — Foreign-source salary received by a resident individual is exempt if the individual has paid foreign income tax on it; tax is treated as paid if it was withheld by the employer and paid to the revenue authority of the country where the employment was exercised.
art. 230(1) and (7) of the Fiscal Code — For a resident of a State with which Romania has a treaty, the rate of tax on income derived from Romania may not exceed the treaty rate; the more favourable rate applies. The questionnaires for establishing tax residence on arrival in and departure from Romania are set by norms (Orders of the Minister of Public Finance Nos 583/2016 and 1099/2016).
National House of Public Pensions (CNPP) — bilateral agreements — CNPP list of States with which Romania has signed bilateral social security agreements: the United States, Canada, Chile, Israel, Quebec, Albania, Korea, North Macedonia, Moldova, Turkey, Serbia and Uruguay.
art. 64(1) of the Fiscal Code — The income tax rate is 10% for income from independent activities, salaries, letting of property, investments, pensions, agricultural activities, prizes and other sources, except the rates expressly provided in Title IV.
art. 97(7) of the Fiscal Code — Income in the form of dividends is taxed at 16% of its amount, the tax being final.
art. 138(a) and art. 156 of the Fiscal Code — Pension contribution (CAS) — 25%; health contribution (CASS) — 10%, for employees and other persons liable under the law.
art. 130 of the Fiscal Code — Residents owe tax on foreign income, determined under the rules of each category of income; foreign pensions have a special regime (para. 2^1); foreign income of a kind that is non-taxable/exempt in Romania gets the same treatment (para. 3); income is declared in the single return by the deadline of art. 122(3), and the tax is computed and paid by the same deadline, taking account of the treaty method (para. 4).
art. 122(3) of the Fiscal Code — The single return on income tax and social contributions is filed for each tax year by 25 May inclusive of the year following the year in which the income was derived.
Art. 4(2)(a) Pakistan–Romania Convention (1999) — Resident of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, resident of the State with which his personal and economic relations are closer (centre of vital interests).
Art. 4(2)(b) Pakistan–Romania Convention (1999) — If the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he is deemed a resident of the State in which he has an habitual abode.
Art. 4(2)(c)–(d) Pakistan–Romania Convention (1999) — Habitual abode in both States or in neither — resident of the State of which he is a national; national of both States or of neither — the competent authorities settle the question by mutual agreement.

Updated 04/11/2026. The result is for information only and is not tax or legal advice. The FBR, other tax authorities and courts may interpret the rules differently, including because of circumstances not covered here, and the law changes with each Finance Act. Consult a qualified adviser before making decisions.

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