In all five treaties, Article 6 gives Romania the right to tax the rent and Article 13 the gain on a sale, because the property is there.
3% of the transaction value if held up to three years, 1% after that, collected by the notary. It is charged on the price, not on the gain (Fiscal Code, Art. 111).
10% after a fixed 20% deduction, about 8% of the gross rent, for residents and non-residents alike (Fiscal Code, Art. 84 and 223).
Israel and the UK give a credit for the Romanian tax. Germany and France exempt the income, and may count it when setting the rate.
The 2024 UK-Romania treaty entered into force on 23.12.2025. In the UK it applies from 6 April 2026 for income tax and capital gains tax.
Romania's tax treaties and your property: the short answer
In all five treaties covered here (Romania with Israel, Germany, France, the United Kingdom and the United Arab Emirates) the rule for property is the same: Romania, where the property is, has the right to tax the rent and the gain on a sale. That right is set in the article on income from immovable property (Article 6 in all five) and in the capital gains article (Article 13 in all five).
What differs is the second step: how your home country avoids taxing the same income again. Israel and the UK give a credit for the Romanian tax. Germany and France exempt the income, and may take it into account when setting the rate on your other income. The UAE treaty leaves the method to UAE law.
Put simply: Romania always taxes first. Where you live decides what happens next.
We cover the Israeli side in detail in our article on the Israel-Romania tax treaty. This article puts the five markets side by side.
What Romania charges, wherever you live
Romania taxes a non-resident individual's rent and property sale under the same rules as a resident (Fiscal Code, Law 227/2015, Art. 223(2)(g)). In 2026:
| Income | Romanian tax | Who collects it | Fiscal Code |
|---|---|---|---|
| Rent from a private individual tenant | 10% of the rent after a fixed 20% deduction, about 8% of the gross rent | You, in the annual return | Art. 64, 84 |
| Rent from a company or other entity that keeps accounts | The same rate, withheld at source by the tenant | The tenant | Art. 84^1 |
| Sale, held up to 3 years | 3% of the transaction value | The notary, on signing day | Art. 111(1)(a) |
| Sale, held more than 3 years | 1% of the transaction value | The notary, on signing day | Art. 111(1)(b) |
Two points matter for the comparison below:
- The Romanian sale tax is charged on the price, not on the gain. You pay it even if you sell at a loss. Your home country usually looks at the gain.
- No treaty reduces these Romanian taxes. The treaties give Romania the right to tax property income in full. The relief happens at home.
Details, dates and the forms are in our guides to rental income tax in Romania and tax on selling property in Romania.
Step 1: Romania taxes first, in every treaty
| Your home country | Treaty with Romania | Rent | Sale | Shares in a property-rich company |
|---|---|---|---|---|
| Israel | Signed 15.6.1997, applies from 1.1.1999; amending protocol signed 3.11.2020, applied in Israel from 1.1.2024 | Art. 6 | Art. 13(1) | Art. 13(4) |
| Germany | Signed 4.7.2001 | Art. 6 | Art. 13(1) | Art. 13(2) |
| France | Signed 27.9.1974, in force 27.9.1975 | Art. 6 | Art. 13(1) | Art. 13(1) |
| United Kingdom | New treaty signed 13.11.2024, in force 23.12.2025 | Art. 6 | Art. 13(1) | Art. 13(4), more than 50% of value from property |
| UAE | Signed 4.5.2015, ratified by Romanian Law 26/2016 | Art. 6 | Art. 13(1) | No specific rule |
The last column matters if you hold the villa through a company. In most of these treaties, selling the shares of a company whose value comes mainly from Romanian property can also be taxed in Romania. Whether to buy personally or through a company is a decision to make with an adviser before signing; we cover it in our article on buying through an SRL.
Step 2: how your home country avoids taxing it twice
There are two methods, and the difference is large.
| Method | How it works | Who uses it for Romanian property |
|---|---|---|
| Credit | Your home country taxes the income too, and deducts the Romanian tax, up to its own tax on the same income | Israel, United Kingdom |
| Exemption | Your home country does not tax the income, but may count it when setting the rate on your other income ("progression") | Germany, France |
With a credit, you end up paying the higher of the two taxes. With an exemption, the Romanian tax is usually the final tax on that income.
Country by country
Israel: a credit, and a trap in the 15% track
Article 24 of the treaty: Israel allows the Romanian tax as a credit, under Israeli law, up to the Israeli tax on the same income. An Israeli resident reports the rent and the sale in Israel.
On rent, the choice of Israeli track decides whether you get the credit at all. On the 15% track (section 122A of the Income Tax Ordinance) there is no credit for the Romanian tax. We explain both tracks in the treaty article, and the Israeli reports in our guide to reporting a foreign property.
The 2020 protocol amended the treaty from 2024. Ask your adviser whether it changes anything in your case.
Germany: exemption, with a progression rule
Article 23(2)(a) of the Germany-Romania treaty: Germany exempts income from Romania that may be taxed in Romania and is not on the credit list in Article 23(2)(b). Rent (Art. 6) and a gain on selling the property itself (Art. 13(1)) are not on that list, so they are exempt in Germany. Gains on shares in a property-rich company (Art. 13(2)) are on the list, so for them Germany gives a credit instead.
The treaty allows Germany to take exempt income into account when setting the rate. But German law excludes rent from property in another EU state from this rule (section 32b(1), second sentence, of the Income Tax Act). Romania is in the EU.
Romania always taxes first. Where you live decides what happens next.
What to ask a German tax adviser (Steuerberater): whether progression applies to a gain on sale, and what you report in Germany even when the income is exempt.
France: exemption, at the effective rate
Article 24(2)(a) of the France-Romania treaty: income that may be taxed in Romania under the treaty is exempt from the French income taxes listed in the treaty, except dividends, interest, royalties and a few other categories, which get a credit. Rent (Art. 6) and gains on property (Art. 13(1)) are exempt.
Article 24(2)(c) lets France calculate the tax on your other income at the rate that applies to your total income, including the Romanian income ("taux effectif"). So Romanian rent can raise the rate on your French income.
What to ask a French adviser: how social contributions apply to Romanian property income, and whether your Romanian property counts for the French real estate wealth tax (IFI). The treaty from 1974 has its own article on wealth (Art. 23), and the answer depends on your situation.
United Kingdom: a new treaty, and a credit
A new UK-Romania treaty replaced the 1975 convention. According to GOV.UK, it entered into force on 23 December 2025 and applies in the UK from 6 April 2026 for income tax and capital gains tax, and in Romania from 1 January 2026. For earlier years, the old convention still applies.
Article 21 of the new treaty: the UK gives a credit for Romanian tax on the same income or gain, under UK law. Article 13(4) adds a clear rule for companies: Romania may tax gains on shares that derive more than 50% of their value from Romanian property.
What to ask a UK adviser: how the credit works against UK tax on the gain, given that Romania taxes the sale price, and how the UK rules on foreign income apply to you.
UAE: Romania taxes, and the UAE decides the method
The Romania-UAE treaty was signed in Dubai on 4 May 2015 and ratified by Romanian Law 26/2016. For an individual, a UAE resident is a person domiciled in the UAE under UAE law (Art. 4(1)(b)). Article 22(b) leaves the relief method, credit or deduction, to UAE law.
For a UAE resident, this means the Romanian tax is often the only tax on Romanian property income. Confirm this with an adviser, especially if you hold the property through a company, and keep a UAE tax residence certificate if you rely on the treaty.
The mismatch on sale: tax on the price, tax on the gain
This is where buyers are most often surprised:
- Romania takes 1% or 3% of the sale price, on signing day, whatever the gain.
- A credit country (Israel, the UK) computes the gain under its own rules, taxes it, and deducts the Romanian tax up to its own tax. If you sold at a loss at home, there may be no home tax to deduct the Romanian tax from.
- An exemption country (Germany, France) does not tax the gain itself, subject to the progression rules above.
Whether the Romanian sale tax is fully creditable at home is a question for your adviser, with the notary's receipt in hand.
When you live in two places
The treaty answer depends on where you are tax resident. If you spend long periods in Romania, you may become a Romanian tax resident too, and then each treaty's residence article (Article 4) decides which country is your home for the treaty. We cover the tests in our article on tax residency.
A checklist for owners abroad
- Find your treaty and its two articles: Article 6 for rent, Article 13 for a sale.
- Know your home country's method: credit or exemption.
- Keep every Romanian tax receipt: the annual return and payment for rent, the notary's receipt for a sale. Without them there is no credit.
- Ask for a tax residence certificate from your home country if a Romanian payer or ANAF asks for it.
- Decide personal or company ownership before signing, with an adviser in each country.
- Plan a sale with both advisers, because the two systems measure it differently.
Frequently asked questions
Which country taxes the rent from my Romanian property first?
Romania, where the property is. All five treaties covered here (Israel, Germany, France, the UK and the UAE) give Romania that right in Article 6. Your home country then relieves the double tax by its own method.
Do I pay tax in Germany or France on Romanian rent?
Under both treaties, Romanian rent is exempt in the home country. France may take it into account when setting the rate on your other income. German law does not apply that rule to rent from property in another EU state. Confirm the details with an adviser in your country.
Does the new UK-Romania tax treaty apply to me?
According to GOV.UK, it applies in the UK from 6 April 2026 for income tax and capital gains tax, and in Romania from 1 January 2026. For earlier years, the 1975 convention applies.
I live in Dubai. Do I pay tax on my Romanian property?
Yes, in Romania: the same rent and sale taxes as any non-resident. The Romania-UAE treaty leaves the relief method to UAE law. Check your position with an adviser, especially if you own through a company.
Is the Romanian sale tax on the profit?
No. It is 3% of the transaction value if you held the property up to three years, and 1% after that (Fiscal Code, Art. 111). Your home country usually looks at the gain, which is why the two calculations need to be planned together.
The bottom line
The five treaties agree on the first step: Romania taxes property income and gains first. They differ on the second: Israel and the UK credit the Romanian tax, Germany and France exempt the income, and the UAE leaves it to its own law.
Before you buy, know which method applies to you. It decides how much of the Romanian tax is the final cost.
If you are planning a purchase in Romania, with us or anywhere else, book a 30-minute call with me. I will not replace your tax adviser, but I will help you reach them with the right questions.
Moti Azulay, Compass Group Romania
Sources: Romanian Fiscal Code, Law 227/2015, consolidated form (legislatie.just.ro), Art. 64, 84, 84^1, 111 and 223 · Israel-Romania tax treaty, Hebrew text and Income Tax (Prevention of Double Taxation) (Romania) Order 2023 (in Hebrew) · Germany-Romania treaty, German Federal Ministry of Finance · German Income Tax Act, section 32b · France-Romania treaty, impots.gouv.fr · UK-Romania tax treaties, GOV.UK · Romania-UAE treaty, ANAF and Law 26/2016
This article is for general information only and is not tax, legal or financial advice. The rules are correct as of 17 October 2026, and they change. How a treaty applies depends on your residence, your ownership structure and the law of both countries. Before any decision, consult a tax adviser in Romania and a tax adviser in your country of residence.
Now you know more.
This article is general information, not legal, tax or financial advice. Consult local professionals before any transaction.
