Romania TVA Return — D300, D394 & RO e-Factura

Establish the client's TVA registration status, filing frequency, and digital access. Confirm their CUI/CIF number and the RO-prefixed VAT number on the ANAF register, verify whether they file monthly (turnover > EUR 100,000 prior year) or quarterly, and check that SPV (Spatiul Privat Virtual) access and RO e-Factura credentials are active. Identify any special regimes: flat-rate agriculture scheme (Art. 315^1), micro-enterprise (impozit pe veniturile microintreprinderilor), or partial exemption status.

Collect all sales invoices, purchase invoices, customs declarations (DVI), and credit notes for the period. From 1 January 2026 all B2B and B2C invoices must have been transmitted via RO e-Factura (CIUS-RO/UBL 2.1) within 5 working days of issuance; invoices not transmitted may be denied input TVA deduction. Download the period's e-Factura XML log from ANAF SPV and reconcile it against the accounting ledger to identify any missing or rejected transmissions before starting the D300.

Classify every transaction by type, counterparty location, VAT rate, and deductibility rule, then assign to the correct D300 rows. Apply the August 2025 rate change (21% standard from 1 August 2025, 11% reduced replacing most former 9%/5% categories, 9% transitional for residential property until July 2026). Apply domestic reverse charge for qualifying supplies (Art. 331): scrap metal, timber, cereals, CO2 allowances, mobile phones/tablets above RON 22,500. Apply the 50% vehicle restriction (Art. 297(4)) and blocked categories (alcohol, tobacco, gifts over RON 100 per item). Flag T2 issues — partial exemption pro-rata, deferred import TVA, exclusive-business-use vehicle claims — for reviewer confirmation.

Prepare the three companion filings due alongside or shortly after D300. D394 (local transactions report, OPANAF 3769/2015) is due on the same deadline as D300 and lists all domestic B2B supplies and acquisitions by supplier/customer CUI; omissions carry penalties of RON 2,000–10,000. D390 VIES (recapitulative statement) is due by the 25th of the following month and covers all intra-EU supplies (Row 6) and intra-EU acquisitions (Row 9). D406 SAF-T is due by the 14th of month M+2 for large taxpayers or last day of M+3 for medium/small taxpayers; ANAF cross-checks D406 against D300 and flags discrepancies requiring a written response within 20 days.

From 2026 ANAF generates a pre-filled D300 (RO e-TVA) from the D406 SAF-T and RO e-Factura data. The taxpayer must review ANAF's pre-filled figures against the prepared D300 working paper and either accept them or submit a written Notificare explaining discrepancies within 20 days. Unexplained differences may trigger a fiscal inspection. This phase reconciles the two sets of figures, documents any variances, and prepares the Notificare where needed.

Submit the finalised D300 via ANAF SPV by the 25th of the month following the period end (monthly filers) or the 25th of the month after quarter end (quarterly filers). Pay any net TVA payable (Row 37) by the same deadline to avoid the 0.02% per day late-interest charge. Upload D394 and D390 VIES by the same deadline. Confirm D406 SAF-T has been submitted by its own deadline. Carry forward any net TVA credit (Row 34) to the next period or elect for a refund (Row 36, subject to ANAF inspection).