SRL construction tax in 2026 (pillar tax): 0.5%, second instalment Monday 2 November, repealed from 2027

On Thursday 1 October 2026, an SRL that holds special constructions still has to pay the second half of the construction tax, called the pillar tax in the press. The date written in the statute is 31 October inclusive. 31 October 2026 is a Saturday, and 1 November is a Sunday, so the first working day is Monday 2 November 2026. This is not the inactivity window for the 2025 annual financial statements, covered in the bank-account and ANAF inactivity guide. It is not the local building tax in Title IX either, with instalments on 31 March and 30 September (Fiscal Code art. 462): that second local instalment fell on Wednesday 30 September 2026. And it is not VAT: the VAT guide stays on the threshold, registration and the return.

The five searches this URL covers, which the existing articles do not take as their subject: (1) the 0.5% construction tax in 2026, who owes it and what stays out of the base, (2) the second instalment, with the move from Saturday 31 October to Monday 2 November, plus interest of 0.02% and a late-payment penalty of 0.01% per day, (3) the 0.25% rate for concession, lease or free use of property on the public or private domain of the state or of an administrative-territorial unit, (4) the 10% bonus and Form 100, position 112, (5) a newly incorporated SRL, with the snapshot on day 30 and payment on 25 January 2027, plus the repeal of Title X from 2027. Figures checked on 1 October 2026 against the consolidated Law no. 227/2015, GEO no. 21/2025, GEO no. 89/2025 and the DGRFP Ploiești presentation of December 2025 published on anaf.ro.

The 0.5% rate applies to the net value of constructions for which no building tax is due under Title IX, held in the patrimony at 31 December 2025 (art. 498(1)(a) of Law no. 227/2015, as amended by GEO no. 21/2025, Official Gazette no. 300/4 April 2025). Net value is the debit balance of the construction accounts minus accumulated accounting depreciation (art. 498(1^2)). Constructions, for Title X, are those in group 1 of the catalogue of normal useful lives (art. 497), the catalogue approved by Government Decision no. 2,139/2004. The decisive filter is not the nickname “pillar”: it is the absence of local building tax. A hall or an office for which the town hall already assesses building tax does not enter ANAF a second time.

The taxpayers are Romanian legal persons, except public institutions, national research-and-development institutes, associations, foundations and other non-profit legal persons, foreign legal persons operating through a permanent establishment in Romania, and legal persons with their seat in Romania incorporated under European law (art. 496(1)). A micro-enterprise SRL is inside the rule. Title X states no turnover floor below which an SRL is exempt. In a finance lease the taxpayer is the user; in an operating lease, the lessor (art. 496(2)). The expense is deductible when computing the taxable result under Title II, corporate profit tax (art. 498(3)); it does not reduce the revenue base of the 1% micro-enterprise tax. The micro-to-profit exit and deductible expenses sit in the corporate profit-tax guide.

Left out: constructions in the territorial sea (art. 498(1^1)); tangible assets in progress (the norm to art. 497); investments in assets held under administration, concession, free use, lease, management location or joint venture, if by 31 December 2025 those investments had not become constructions under art. 497 (art. 498(1^3)); constructions exempt from building tax under Title IX (art. 498(1^4)). Increases and decreases during 2026 do not recompute this year’s tax; they count only for the following year (art. 498(2)) — and the following year, 2027, is the year of repeal, so a December 2026 commissioning does not by itself create a 2027 tax. Example on 1 October 2026: an industrial platform, net book value at 31 December 2025 of RON 2,000,000, with no local building tax. Annual tax: RON 2,000,000 × 0.5% = RON 10,000. Two equal instalments of RON 5,000.

Art. 499(1) requires the tax to be computed and declared by 25 May inclusive of the year for which it is due. In 2026, 25 May was a Monday, a working day: the deadline did not move. Art. 499(2), as set by GEO no. 156/2024 (Official Gazette no. 1334/31 December 2024), splits payment into two equal instalments, by 30 June and by 31 October inclusive. 30 June 2026 was a Tuesday. 31 October 2026 is a Saturday. Art. 75 of Law no. 207/2015 (the Fiscal Procedure Code) sends the calculation of time limits to the Civil Procedure Code, unless fiscal law provides otherwise. Art. 181(2) of Law no. 134/2010 says that when the last day falls on a non-working day, the limit runs until the next working day. 1 November 2026 is a Sunday, not a public holiday, but it is a non-working day. The first working day is Monday 2 November 2026. Do not confuse this civil-procedure art. 181 with art. 181 of the Fiscal Procedure Code: that one is the undeclared-tax penalty, 0.08% per day.

On the RON 10,000 example, the second instalment is RON 5,000, payable at the latest on Monday 2 November 2026. Interest on amounts paid after the due date is 0.02% for each day of delay (art. 174(5) of the Fiscal Procedure Code), from the day after the due date through the day the amount is settled, inclusive. The late-payment penalty is 0.01% per day and does not replace the interest (art. 176). If you pay on Wednesday 2 December 2026, the days of delay are 3 November–2 December, that is 30 days: RON 5,000 × 0.02% × 30 = RON 30 interest and RON 5,000 × 0.01% × 30 = RON 15 penalty, RON 45 in total. Amounts not declared, or declared incorrectly, and assessed by the tax authority draw the undeclared-tax penalty of 0.08% per day (art. 181(1) of the Fiscal Procedure Code): on the same RON 5,000 and 30 days, RON 120, besides interest. A payment made on Friday 30 October avoids a Monday bank cut-off; the shifted legal due date remains 2 November, not the Friday before.

There is a conflict in the texts which press reports do not close. Art. 154(3) of the Fiscal Procedure Code replaces, for claims administered by ANAF, assessed by a tax return and paid into the single account, a due date other than the 25th with the 25th of the month set by the statute. Applied mechanically, 31 October would become 25 October 2026, which is a Sunday, so Monday 26 October 2026. Art. 499(2), later and specific, and the DGRFP Ploiești presentation of December 2025 on anaf.ro, keep 30 June and 31 October. On 1 October 2026 the date you follow for the second instalment is 31 October, moved to Monday 2 November. If the Virtual Private Space shows 26 October, pay the date in the ANAF ledger: the later act did not expressly repeal art. 154(3), and the two texts do not say the same thing. For a modified fiscal year (art. 16(5)), the return is due by the 25th of the fifth month, and the instalments fall on the last day of the sixth month and of the tenth month (art. 499(2^1)), not automatically on 30 June and 31 October.

The 0.25% rate is not a discount on the 0.5% rate for small firms. Art. 498(1)(b) applies it to the value of constructions under contracts of administration, concession, free use or lease, only when the assets belong to the public or private domain of the state or of administrative-territorial units, exist at 31 December 2025 and are not charged building tax under Title IX. The tax is owed by the person who holds them under administration, concession, free use or lease, not by the public owner. Contracts concluded after GEO no. 21/2025 entered into force must state the value of the constructions (art. XII(2) of the ordinance). For older contracts that did not state a value, the owners had to communicate it by 15 May 2025.

Rent on a flat or an office from a private owner is not this rate. The registered-office guide explains the loan-for-use agreement and the lease filed with the Trade Register. A natural-person landlord may owe local building tax at the town hall; your SRL does not pick up Title X merely because the address in the articles is a studio. Example of 0.25%: a concession of a warehouse on a city’s private domain, contract value RON 800,000, with no building tax. Annual tax: RON 800,000 × 0.25% = RON 2,000. Instalments: RON 1,000 by Tuesday 30 June 2026 and RON 1,000 by Monday 2 November 2026. If that same warehouse is already taxed at the town hall as a building, letter (b) does not apply.

The two rates do not stack on the same asset. Letter (a) is your own patrimony, 0.5% on net book value. Letter (b) is the public asset you use, 0.25% on the value in the deed, owed by you as holder. An SRL can have both in the same year: its own platform of RON 2,000,000 (RON 10,000) plus the concessioned warehouse of RON 800,000 (RON 2,000), total RON 12,000, instalments of RON 6,000. Off-balance-sheet accounts do not enter the base under letter (a) (the norm to art. 498). Check the trial balance at 31 December 2025, not the October 2026 balance: art. 498(2) freezes the base at the previous year-end.

Art. 499(4^1), introduced by GEO no. 21/2025, gives a bonus of 10% of the tax to taxpayers who declare and pay the entire annual tax early, by 25 May inclusive (or by the 25th of the fifth month, on a modified fiscal year). On RON 10,000, the bonus is RON 1,000, so you pay RON 9,000. 25 May 2026 was a Monday. On 1 October 2026 the window is closed: you no longer obtain 10% by paying the second instalment before 2 November. Paying the balance in October settles the remaining RON 5,000; it does not reopen the bonus. A taxpayer who took the bonus and then ceases during the year recomputes it against the prorated tax (art. 499(4^2) and art. 498(2^1): the annual tax divided by 365 calendar days, multiplied by the days of existence).

The return is Form 100. Order of the ANAF president no. 649/2025 (legislatie.just.ro) places the liability at position 112, “Construction tax”, in the nomenclature of liabilities to the state budget. Row 1 is the amount due. Row 2, “Bonus”, is completed only by someone who meets art. 499(4^1). Row 3, “Amount to pay”, is row 1 minus row 2 for those with the bonus; everyone else enters the amount from row 1. The electronic structure of Form 100 on anaf.ro, the version after the order of 13 May 2025, ties the liability to code 701 and budgetary code 20A070400, with a flag for a newly incorporated taxpayer (due date 25 January) and for the bonus. It is not the micro-tax row and not the profit-tax row: same form, different position. The micro guide explains Form 100 for the 1% tax on revenue.

If you never filed by 25 May and you have constructions in the base, the November instalment does not replace the return. The 0.08% per day undeclared-tax penalty is computed on the liability set by a decision, from the day after the due date until payment. A consultancy SRL with no group-1 asset and no contract on the public domain does not file position 112 at nil just to “be in order”: the liability arises when the constructions in art. 498 exist. If the trial balance at 31 December 2025 is unclear (a construction account mixed with buildings already taxed at the town hall), separate the value for which Title IX has already been applied; the norm to art. 498 says you deduct the book value of constructions that were the base for building tax, not a figure invented in October.

An SRL incorporated in 2026 does not pay the 30 June and 31 October instalments for the year of its birth. Art. 498(2^2) says it owes the tax starting with the year of incorporation, on the constructions in the patrimony and/or under contracts of administration, concession, free use or lease existing on the 30th day inclusive from registration, if that day does not fall after the last day of the incorporation year. The annual tax so determined is recomputed: divided by 365 calendar days and multiplied by the days from registration through 31 December inclusive. Art. 499(4) moves both the return and the payment to 25 January inclusive of the following year. 25 January 2027 is a Monday, a working day: it does not move further.

Example with registration on Thursday 1 October 2026. The 30th day inclusive is Friday 30 October 2026. If on that day the patrimony contains a construction with a net value of RON 365,000, outside building tax, the theoretical annual tax is RON 365,000 × 0.5% = RON 1,825. The days from 1 October through 31 December 2026 inclusive are 92 (31 + 30 + 31). Tax due: RON 1,825 / 365 × 92 = RON 460, to be declared and paid on Monday 25 January 2027, not on Monday 2 November 2026. If on 30 October you have no construction under art. 498, the fraction is zero. A flat rented from a natural person, used as the registered office, does not enter the day-30 snapshot. The steps after the certificate — the private virtual space, the account, the tax vector — are in the post-incorporation checklist; that page does not compute Title X.

GEO no. 89/2025 (Official Gazette no. 1203/24 December 2025) repeals Title X from the year 2027, or from the modified fiscal year that begins in 2027. 2026 is the last year in which the tax is computed. The repeal is not written as a cancellation of tax already born for 2026: art. 499(4) still has a company incorporated in 2026 declare and pay the 2026 fraction on 25 January 2027. Read together, the two texts send the January payment to the 2026 tax, not to a 2027 tax. If ANAF publishes an instruction that says otherwise, that instruction prevails — on 1 October 2026 the official presentation still describes the liability under Title X as in force. A company that ceases in 2026 declares and pays the prorated tax by the date it ceases to exist; if cessation is after the declaration deadline, a corrective return is filed (art. 499(3)).

Walk through the steps before Monday 2 November 2026. The figures are those in force on Thursday 1 October 2026.

Tavoris prepares the SRL incorporation dossier for the Trade Register, from the identity document and the registered-office contract. It does not decide whether a platform falls in group 1, it does not compute 0.5% or 0.25%, it does not file Form 100 and it does not pay the instalment of Monday 2 November 2026 or the amount of Monday 25 January 2027.

After the certificate, Title X is yours, with your accountant. The incorporation dossier is the list of documents for the Trade Register. The post-incorporation guide covers the private virtual space and the account. This article covers only the construction tax in the last year Title X still exists.

Informational guide as of 1 October 2026. Law no. 227/2015 (arts. 496–499), GEO no. 156/2024, GEO no. 21/2025, GEO no. 89/2025, ANAF order no. 649/2025, Law no. 207/2015 (art. 75, art. 154(3), art. 174, art. 176, art. 181), Law no. 134/2010 (art. 181(2)), Government Decision no. 2,139/2004 and the DGRFP Ploiești presentation of December 2025 may be updated. The tension between art. 499(2) and art. 154(3) is unresolved in the text read on this date. Check anaf.ro and legislatie.just.ro, including the due date in the Virtual Private Space. This is not tax, accounting or legal advice.