CORPORATE LAW: NEW RULES FOR THE REGISTRATION OF SECONDARY OFFICES

The fiscal framework regarding the registration of secondary offices with employees was reviewed by the Ordinance no. 6 of 30.01.2026. The normative act clarifies and adjusts the obligations previously introduced in the Fiscal Procedure Code by Law no. 245/2025, regarding the tax declaration and registration of entities organized at an address different from the registered office. The amendments concern the conditions and documentation required for the tax registration of these structures.

Changes to the tax regime of secondary offices

Where a taxpayer/payer has organized several secondary offices within the same administrative-territorial unit/subdivision, they must designate a single "determined secondary office", which will be the only one to be assigned a Tax Identification Code (CIF). The other offices will be included in the structure of the determined secondary office, and the CIF previously assigned, in principle, will be deleted.

The deadline for declaring the determined secondary office is 30 days from the date of establishment of the first secondary office and it will be notified to the fiscal body subordinated to the ANAF with jurisdiction over the territorial area where the activity of the secondary offices is carried out.

Exceptionally, if all secondary offices are located in the same administrative-territorial unit/subdivision where the taxpayer has the fiscal domicile, the tax on income from salaries or similar income is declared and paid based on the taxpayer's CIF, without designating a specific secondary office.

At the same time, the ordinance also suspends, until June 30, 2026, included, the obligation to register for tax purposes secondary offices having at least one employee, as well as the related sanctions for taxpayers having already established secondary offices on the date of entry into force of Law no. 245/2025.  For them, the 30-day timeframe starts running from June 30, 2026.

Article III of the Ordinance provides that, by June 30, 2026 included, taxpayers with multiple secondary offices with employees, located in the same administrative-territorial unit/subdivision, shall designate the determined secondary office, without the obligation to register for tax purposes until this date.

The notification procedure to ANAF will be established by Order of the President of ANAF, issued within 30 days from the date of entry into force of the Ordinance.

We consider necessary to bring some clarity on this last matter. Given that, at this time, there is no regulated procedure by which taxpayers can notify ANAF regarding the choice of the determined secondary office, it can be appreciated that the 30-day period provided for by Ordinance no. 6/2026 in art.

I could start running on the date of entry into force of the Order of the President of ANAF establishing this procedure. In this interpretation, in practice, if a taxpayer establishes one or more secondary offices by the time the Order enters into force and given the impossibility to notify ANAF in a procedurally correct form, it would theoretically benefit from another timeframe adding to the initial 30 days.