In brief
In Romania you are a tax resident if you have a domicile (domiciliu) there, if the centre of your vital interests is there, or if you have stayed there for more than 183 days within 12 consecutive months. In Israel residency is determined by the centre of life, with rebuttable presumptions based on days of presence. Where residency exists in both countries, Article 4(2) of the tax treaty decides by permanent home, centre of interests, habitual abode and nationality, in that order.
Key takeaways
- 1In Romania: more than 183 days within 12 consecutive months creates residency, and according to the accepted explanation, from the day of arrival.
- 2Within 30 days of the day on which 183 days of presence are completed, a questionnaire for determining tax residency on arrival is filed with ANAF.
- 3In Israel: 183 days in a year, or 30 days in a year and 425 days over three years, create a presumption that the centre of life is in Israel; the presumption is rebuttable.
- 4In dual residency, the treaty decides by permanent home, centre of vital interests, habitual abode and nationality.
- 5Under section 100A of the Income Tax Ordinance, a person who ceases to be an Israeli resident is deemed to have sold his or her assets on the day before; payment can be deferred until the sale.
Families planning to move to Bucharest, or to spend a substantial part of the year there, ask “from which day are we Romanian residents?”. There is no single such day. Each country has its own tests, which are applied according to the facts, and forms that must be filed on time. And whoever meets both tests at once, which almost always happens in the first year, needs the tax treaty to know which country holds the primary taxing right.
When do you become a tax resident in Romania?
Article 7 of the Romanian Tax Code (Codul fiscal, Law 227/2015) lists four alternatives, each of which is sufficient on its own for the tax authority ANAF to regard an individual as a resident: an official domicile (domiciliu) in Romania; the centre of the main personal and economic ties being in Romania; cumulative physical presence of more than 183 days in any window of 12 consecutive months ending in the calendar year; or, for a Romanian citizen, working abroad in the service of the Romanian state.
| Alternative | What is examined in practice |
|---|---|
| domiciliu | An official residential address in Romania |
| Centre of interests | Where the family, work and assets are |
| Days of presence | More than 183 days in a 12-month window |
| State employee | A Romanian citizen posted abroad on behalf of the state |
Alongside these alternatives, ANAF takes into account supporting indicators, such as a Romanian car or driving licence and membership of the local social security and health system, but not as an independent test. The accepted explanation is that whoever crosses the days threshold is regarded as a resident from the date of entry, whereas whoever has moved the centre of his or her life to Romania becomes a resident on the basis of a declaration.
Within 30 days of the day on which 183 days of presence are completed, a questionnaire for determining tax residency on arrival is filed with ANAF.
What is the financial significance of Romanian residency?
The difference is material. A Romanian resident is liable to tax on all income, anywhere in the world, and the personal income tax rate is generally a flat 10%, with separate arrangements for dividends, capital gains and the sale of property. Whoever remains a non-resident pays tax in Romania only on income generated there, for example rent from the property.
Which form is filed with ANAF, and when?
As soon as the stay exceeds 183 days, a 30-day window opens for filing the arrival questionnaire (Chestionar pentru stabilirea rezidenței fiscale a persoanei fizice la sosirea în România), on the basis of which ANAF determines your status.
- The questionnaire is usually accompanied by the passport, proof of residence in Romania and an ownership or lease contract for the dwelling.
- If you wish to be regarded as Israeli residents under the treaty, attach a certificate of residency from the Israel Tax Authority, with a certified translation.
- ANAF's answer arrives within 30 days: full liability in Romania, or liability on Romanian income only.
- Departure also has its own questionnaire, which is filed a month before leaving.
How does Israel determine who is a resident?
In Israel the basic test, under section 1 of the Income Tax Ordinance, is where a person's “centre of life” is. The assessing officer considers the whole picture: where the home is, where the family lives, where the person works, where the economic interests are and in which organisations the person is active. To facilitate the decision, the Ordinance sets two numerical presumptions:
- Presence in Israel of 183 days or more during a single tax year;
- or presence of 30 days or more in the tax year, where the total number of days in that year and the two preceding years reaches at least 425.
Both sides may rebut the presumptions: the taxpayer and also the Israel Tax Authority. A person claiming not to be an Israeli resident files Form 1348, a declaration of residency, with the annual return.
| Subject | Romania | Israel |
|---|---|---|
| Substantive test | Domicile or centre of vital interests | Centre of life, according to the totality of ties |
| Days test | More than 183 days in 12 consecutive months | Presumption: 183 days in a year, or 30 days and 425 over three years |
| Form | Arrival questionnaire, within 30 days of the 183 days | Declaration of residency, Form 1348 |
| Scope of taxation for a resident | Worldwide income, generally 10% | Worldwide income, according to brackets |
What does the treaty provide when you are a resident of both countries?
In the first year of the move almost everyone falls between two stools: more than half a year in Bucharest, but with an apartment, a workplace or children who have remained in Israel. In such a case Article 4(2) of the treaty between Israel and Romania applies tests in sequence, and you move to the next stage only if the previous one did not decide:
- Where you have a permanent home available. A home in both countries, or in neither, passes the question on.
- Where the ties are stronger. Family, livelihood and assets, that is, the centre of vital interests.
- Where you stay habitually. The habitual abode test.
- Which country's passport. And if nationality does not decide either, the authorities of both countries reach agreement between themselves.
A villa in Romania is a permanent home available, and a vacant apartment in Tel Aviv is also a permanent home. In such a situation the decision moves to the centre of interests: family, work, assets and ties. ANAF itself notes that a person who keeps his or her main home in the country in which he or she lived and worked, and where his or her family and assets are located, can show that his or her centre of interests has remained there. Purchasing a property in Romania does not by itself make you Romanian residents.
What happens in Israel when you cease to be residents?
- Exit tax. Section 100A of the Ordinance treats a person who ceases to be an Israeli resident as if he or she had sold his or her assets on the day before the severance. The liability arises at that moment, although payment can be deferred until the asset is actually sold.
- Real estate taxation. Non-resident status may change eligibility for “single apartment” relief from purchase tax and land appreciation tax, and a property in Romania may be taken into account.
- National Insurance. The National Insurance Institute examines residency under its own rules, which are not identical to those of income tax.
- Status in Romania. Residency for tax purposes does not confer a right of residence; Israelis need to regularise their legal status in Romania separately.
What to do before the move and how we assist
The first year of a move should be built deliberately: when you arrive, what remains in Israel and which forms are filed on each side. We help build the legal timeline of the move, coordinate between the Israeli tax adviser and a Romanian tax adviser, and prepare the documents required by ANAF. Filings with the Romanian authorities and Romanian tax advice are handled by professionals licensed in Romania.
What is stated here is general information correct as of October 2026 and does not constitute legal or tax advice. Determining residency depends on the facts of each family, and each country examines it according to its own law. Before moving, consult a tax adviser versed in Israeli and Romanian law.
Frequently asked questions
After how many days in Romania do you become a tax resident?
Under the Romanian Tax Code, after more than 183 days within 12 consecutive months. You can also become a resident earlier, if your domicile or centre of vital interests has moved to Romania. In dual residency, the treaty decides.
Does buying a villa in Romania make me a Romanian tax resident?
Not in itself. A villa is a permanent home available, but if you also have a permanent home in Israel, the decision moves to the centre of interests. A person who lives and works in Israel and visits the property usually remains an Israeli resident.
Can you be an Israeli resident and a Romanian resident in the same year?
Under the domestic law of each country, yes. The treaty determines which country holds the primary taxing right, according to the order of the tests: permanent home, centre of interests, habitual abode and nationality.
What is exit tax in Israel?
Under section 100A of the Income Tax Ordinance, the assets of a person who ceases to be an Israeli resident are deemed sold on the day before residency ceases. Payment of the tax can be deferred until the actual sale.
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The information in this guide is general in nature and does not constitute legal or tax advice on any specific transaction. Every transaction is assessed on its own facts.