Tax residence in Romania for Singapore taxpayers

Romania treats you as resident if your domicile or 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. Singapore decides your status for the calendar year with 183 days or more of presence or employment. If both countries claim you, Art. 4(2) of the Romania–Singapore Agreement of 2002 decides; the salary exemption of Art. 15(2) applies only if your employer is resident in your state of residence.

Check your status: Singapore and Romania

Free, no sign-up, about 3 minutes. Conclusion under Singapore's Income Tax Act 1947, compared with the law of Romania and the tax treaty (DTA).

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 non-resident

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 Singapore 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 Singapore; 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 Singapore (art. 59(5) of the Fiscal Code) — a Certificate of Residence issued by IRAS. If Singapore also treats you as resident, Art. 4(2) of the Romania–Singapore Agreement 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 Singapore also treats you as resident, Art. 4(2) of the Agreement 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 while Singapore looks at the calendar year, you can at the same time be resident in Singapore — typically in the year you move, for example with 183 days in Singapore in that calendar year or under IRAS's two- or three-year rules. A permanent home available only in Singapore still makes you a resident of Singapore under Art. 4(2) of the Agreement; 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).

What else to know

Which treaty applies: the Romania–Singapore Agreement (2002). The Agreement signed at Singapore on 21 February 2002 (Romanian Law No. 475/2002) has been in force since 28 November 2002; it applies in Romania from 1 January 2003 and in Singapore from Year of Assessment 2004. It is modified by the MLI (new preamble and a principal purpose test), which does not change Article 4. Residence tie-breaker: Art. 4(2) — permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement (Art. 27). Employment: Art. 15 (183 days in any 12-month period commencing or ending in the calendar year, and an employer resident in your State of residence); private pensions: Art. 18 — State of residence only; limitation of relief (remittance basis): Art. 24; relief: Art. 25 — credit in both countries.
Different counting periods: a rolling 12 months in Romania. Singapore decides your residence for the calendar year: 183 days or more of presence or employment in that year, normal residence as a citizen or Permanent Resident, or IRAS's two- and three-year rules. 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 183-day limit for salary in Art. 15(2)(a) of the Romania–Singapore Agreement counts any period of twelve months commencing or ending in the calendar year concerned. Check every 12-month window, not just one calendar year.
How Singapore and Romania relieve double taxation. If Singapore is your state of residence, Romanian income is generally not taxed in Singapore — foreign-sourced income received by a resident individual is exempt (s. 13(7A)); where Singapore does tax it, the Romanian tax is credited against the Singapore tax on that income (Art. 25(2)) — claim the foreign tax credit in your Singapore return. Under Art. 24, a Romanian exemption or reduced rate under the Agreement on income that Singapore taxes only when remitted applies only to the amount remitted to or received in Singapore. If Romania is your state of residence, Romania credits the Singapore tax on income Singapore may tax against Romanian tax, up to the Romanian tax on that income, per country and type of income (Art. 25(1); 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 Singapore. Pay for work physically done in Romania is Romanian-source income. If Singapore is your treaty residence, Romania does not tax it only if all three conditions of Art. 15(2) are met: not more than 183 days in Romania in any period of twelve months commencing or ending in the calendar year concerned; pay paid by, or on behalf of, an employer who is a resident of Singapore — an employer resident in a third country does not qualify; 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 Singapore such pay is foreign-sourced income, generally exempt for a resident individual (s. 13(7A)); where Singapore does tax it, the Romanian tax is credited (Art. 25(2)).
Certificates of residence and treaty rates in Romania. To benefit from the Agreement in Romania — for example a reduced withholding rate on Romanian dividends, interest or royalties — give the Romanian payer a certificate of tax residence from Singapore: the Certificate of Residence issued by IRAS. 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, Singapore does not. 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)). Singapore has no split year: it decides your status for the whole calendar year. Where both countries treat you as resident for the same period, the Agreement 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 Singapore 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 Romania–Singapore agreement on the CNPP list. Singapore is not on the CNPP list of States with which Romania has bilateral social security agreements, and EU Regulation 883/2004 does not apply to Singapore. Romanian social contributions (CAS 25%, CASS 10% for employees) may therefore be due on work in Romania under Romanian rules.

How dual residence is resolved

If both countries treat you as a resident, Art. 4(2) of the treaty applies: Agreement between the Republic of Singapore and Romania for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital, with Protocol, signed at Singapore on 21 February 2002 (Romania: Law No. 475/2002, Monitorul Oficial No. 580 of 6 August 2002), as modified by the MLI. The tests are applied in order — permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement between the tax authorities.

The treaty in detail: income, rates, the 183-day rule →

Terms you will come across in Romania

domiciliu: domicile — the main home declared and recorded in the Romanian identity card; it makes you resident whatever the days
centrul intereselor vitale: centre of vital interests — family, a Romanian employer, business, property and bank accounts, assessed as a whole
chestionarul la sosire: arrival questionnaire, filed with ANAF within 30 days after 183 days of presence are reached
Declarația unică: the single return in which foreign income is declared, by 25 May of the following year
certificat de rezidență fiscală: certificate of tax residence, needed for treaty rates on Romanian income
ANAF: the Romanian tax administration; it issues Romanian certificates of residence on request

Questions

How are the 183 days counted in Romania?

More than 183 days in any 12 consecutive months ending in the calendar year, counting days of arrival and departure. Singapore counts 183 days or more within the calendar year.

Does Romania tax my salary if my Singapore employer sends me there for three months?

Not if Singapore is your treaty residence, you are in Romania for not more than 183 days in any twelve-month period commencing or ending in the calendar year, the employer is resident in Singapore and no Romanian permanent establishment bears the pay (Art. 15(2)).

How do I prove I am resident in Singapore to a Romanian payer?

Give the payer a Certificate of Residence issued by IRAS; Romania then may not withhold more than the treaty rate (arts 59(6) and 230(1) of the Fiscal Code).

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.
Guvernul României, Punct de vedere privind propunerea legislativă Bp. 89/2021 (Senat, L123/2021) — redă art. 87 și art. 91 alin. (1) din Codul civil (Legea nr. 287/2009, republicată) — 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)).
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) of the Romania–Singapore Agreement (2002) — Dual-resident individual: (a) resident only of the State in which he has a permanent home available to him; with 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 he has no permanent home available in either State, of the State in which he has an habitual abode; (c) habitual abode in both States or in neither — the State of which he is a national; (d) national of both States or of neither — the competent authorities settle the question by mutual agreement (Art. 27). The MLI does not change Article 4.
IRAS — List of DTAs, Limited DTAs and EOI Arrangements (updated 4 February 2026) — Singapore's comprehensive Avoidance of Double Taxation Agreements (DTAs), limited agreements covering only shipping and air transport income, and exchange-of-information arrangements; the texts of the agreements are published by IRAS.
s. 2(1) Income Tax Act 1947 (definition of «resident in Singapore», para (a)) — An individual is resident in Singapore if, in the year preceding the year of assessment, he or she resides in Singapore except for such temporary absences as may be reasonable and not inconsistent with a claim to be resident; also resident is a person who in that year was physically present or exercised employment in Singapore (other than as a company director) for 183 days or more.
Art. 15(2) of the Romania–Singapore Agreement (2002) — Remuneration of a resident of one State for employment exercised in the other State is taxable only in the State of residence if (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any period of twelve months commencing or ending in the calendar year concerned, (b) it is paid by, or on behalf of, an employer who is a resident of the first-mentioned State (the State of residence), and (c) it is not borne by a permanent establishment or a fixed base which the employer has in the other State.
IRAS — «Apply for Certificate of Residence» (updated 20 August 2026) — A Certificate of Residence (COR) for a state with which Singapore has a DTA is applied for through IRAS's online application; the form depends on the applicant's profile (Singapore citizen or PR employee, self-employed person, foreign employee with or without Singpass). Processing takes 2–3 weeks; the letter is available on myTax Portal if digital notices were chosen, otherwise it is mailed. A foreign tax authority's own form can be certified by IRAS on request (XLSX application and original form sent by post).
IRAS — «Working out my tax residency» (updated 12 May 2026) — A Singapore citizen or permanent resident who normally resides in Singapore, except for temporary absences, is a tax resident. A foreigner is resident for a year of assessment if, in the preceding calendar year, he or she stayed or worked in Singapore for at least 183 days, or stays or works in Singapore continuously for three consecutive years (then for all three years, even with fewer than 183 days in the first and third). A foreign employee whose employment spans two calendar years is resident for both years if the period of employment, together with the stay immediately before and after it, is a continuous period of at least 183 days (not for company directors, public entertainers and professionals). Days include weekends and public holidays, and temporary absences (leave abroad, business trips) connected with the employment in Singapore.
Art. 25 of the Romania–Singapore Agreement (2002) — Romania (para. 1): deduction from the tax on the income of a Romanian resident of an amount equal to the income tax paid in Singapore on income that may be taxed in Singapore, not exceeding the part of the Romanian tax attributable to that income. Singapore (para. 2): subject to its laws on credit for foreign tax, the Romanian tax paid, directly or by deduction, is allowed as a credit against the Singapore tax payable on that income.
Art. 24 of the Romania–Singapore Agreement (2002) (limitation of relief) — Where the Agreement exempts income from sources in one State or reduces the tax on it there, and under the law of the other State the income is taxed by reference to the amount remitted to or received in that other State, the exemption or reduction applies only to the amount remitted or received; not for the Government of Singapore and approved persons.
s. 13(7A) ITA 1947 — Exempt is income from sources outside Singapore received in Singapore: (a) by a non-resident individual; (b) from 1 January 2004 — by a resident individual, where the Comptroller is satisfied that the exemption is beneficial to him or her; the exemption does not cover such income received through a partnership in Singapore.
IRAS — «Claiming foreign tax credit» — Where foreign income is taxable in Singapore and foreign tax has been paid on it, a resident can claim a foreign tax credit in the return; the credit is the lower of the foreign tax paid and the Singapore tax payable on that income.
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.
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).
ITA 1947, s. 2(1) («resident in Singapore»), 62(4)–(5), 73(1); IRAS — «Working out my tax residency» (updated 12 May 2026) — Status is set for the whole calendar year and applies to the following Year of Assessment. A foreigner arriving is resident for that year with 183 days of presence or employment, or under the two-year or three-year administrative rules; a holder of a work pass valid for at least one year is provisionally treated as resident, and the status is reviewed at tax clearance. A person chargeable to tax notifies IRAS within one month of arrival.
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) of the Romania–Singapore Agreement (2002) — A dual-resident individual is deemed to be a resident only 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, of the State with which his personal and economic relations are closer (centre of vital interests).
Annex A to the IRAS text — effects of the MLI (Romania–Singapore) — The MLI replaces the preamble, deletes the main-purpose clauses in Arts 11 and 12 and adds a principal purpose test (Art. 29A); Article 4 is not changed.
Art. 4(2)(b) of the Romania–Singapore Agreement (2002) — If the State in which he has his centre of vital interests cannot be determined, or if he has no permanent home available to him in either State, he is deemed to be a resident only of the State in which he has an habitual abode.
Art. 4(2)(c), (d) of the Romania–Singapore Agreement (2002) — If he has an habitual abode in both Contracting States or in neither of them, he is deemed to be a resident only of the State of which he is a national (c); if he is a national of both States or of neither of them, the competent authorities settle the question by mutual agreement (d; procedure in Art. 27).

Updated 10/11/2026. The result is for information only and is not tax or legal advice. IRAS, other tax authorities and courts may interpret the rules differently, including because of circumstances not covered here, and the law can change with each annual Budget. Consult a qualified adviser before making decisions.

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