Romania
A. Progress in the implementation of the minimum standard
Romania has 88 tax agreements in force, as reported in its response to the Peer Review questionnaire. One of those agreements, the agreement with Spain, complies with the minimum standard.
Romania signed the MLI in 2017, and deposited its instrument of ratification on 28 February 2022, listing its non-compliant agreements. The MLI entered into force for Romania on 1 June 2022. The agreements modified by the MLI come into compliance with the minimum standard once the provisions of the MLI take effect.
Romania reserved the right to delay the entry into effect of the provisions of the MLI until Romania has completed its internal procedures for this purpose with respect to each of its listed agreements.1 Romania has not yet notified that it completed its internal procedures for the entry into effect of the MLI with respect to any of its agreements.
Romania has not listed its agreement with Germany under the MLI. This agreement will therefore not, at this stage, be modified by the MLI. Germany has listed its agreement with Romania under the MLI. Romania indicated in its response to the Peer Review questionnaire that the agreement with Germany does not give rise to material treaty-shopping concerns for Romania.
Romania is implementing the minimum standard through the inclusion of the preamble statement and the PPT.2
B. Conclusion
Germany has listed its agreement with Romania under the MLI, which amounts to a request to implement the minimum standard.
Romania has developed a plan for the implementation of the minimum standard in its agreement with Germany. Romania indicated in its response to the Peer Review questionnaire that bilateral discussions would be pursued with respect to that agreement.