Law Office Services — Tax Law

In tax law, the “problem” is rarely just an amount written in a decision. The real problem is the chain reaction: operational blockages, bank account garnishments, cash-flow pressure, reputational risk, delayed contracts, difficulty paying salaries or suppliers and, sometimes, the opening of a criminal file triggered by the findings of a tax audit. In these situations, the difference is made by the strategy adopted in the first days: how you respond, which documents you use, what you admit and what you do not, what you challenge, in what order and how you avoid letting the tax defence create problems in another procedure.

This page explains, in a clear and practical format, my tax consultancy and tax litigation services: from preparation for an ANAF audit to administrative challenges against tax acts, administrative-tax litigation, suspension requests, defence in tax enforcement, VAT disputes, refunds, transfer pricing, foreign companies operating in Romania and situations where a tax audit moves close to the criminal-law area.

In tax matters, a strong file is not built on impressions. It is built on documents, chronology and proof. It matters when the document was served, how it was communicated, what was sent during the audit, what ANAF recorded, which documents were ignored, what commercial explanation exists and how all this connects with the deadline for the administrative challenge, suspension request or enforcement challenge. A coherent tax position must be usable in the administrative appeal, in court and in practical discussions about garnishments, guarantees, instalment plans or operational unblocking.

The information below is general and does not replace legal advice on a specific matter. In tax files, the documents, date of service, audit chronology, accounting records and criminal-risk indicators can materially change the correct solution. For a first review, send the acts received from ANAF, proof of service and a short chronology of the audit or enforcement measures.

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In 30 seconds: how I can help

Useful tax assistance is not limited to drafting an appeal after the audit has ended. In many cases, the real work is to build the file during the audit: which documents you send, which explanations you give, what you put in writing, how you avoid contradictions, how you preserve proof of communication and how you prepare the next stage if ANAF issues an assessment decision, orders precautionary measures or starts enforcement.

For the main English page for this practice area, see Tax Law and Tax Litigation Lawyer in Bucharest. For all practice areas, see Law office services in Bucharest and Romania.

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Practical working principles

1. Deadline control. In tax matters, many rights are lost if you react late or incorrectly. The date of service, challenge deadline, enforcement deadline and timing of suspension must be checked immediately.
2. A file built on documents. In tax litigation, the story matters far less than the evidence. Contract, invoice, payment, delivery, receipt, transport, correspondence and economic logic must support each other.
3. Two tracks where necessary: tax and criminal. If there is criminal risk, the strategy must be coordinated. An explanation that helps fiscally may become problematic criminally if it is not checked against documents and chronology.
4. Operational continuity. The goal is to reduce blockages: garnishments, seizures, freezing measures, suspensions and cash-flow pressure. The tax file must be assessed through its effect on ongoing activity.
5. Implementable result. The goal is not only paper annulment, but practical effect: amounts, interest, penalties, accounts, enforcement, tax records, refunds or unblocking.
6. Consistency across stages. What you write during the audit may appear in the administrative challenge, in court or in a criminal file. Responses must be consistent with documents and with the future position.
7. Costs and risks anticipated early. Before litigation, court costs, security for suspension, expert reports, account freezes and enforcement risk must be estimated.

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Preventive tax consultancy and business decisions

Good tax advice is not about aggressive optimisation. It is about predictable, documented and defensible decisions: choosing the structure, understanding risk, preparing justifications, aligning contracts with real flows and reducing exposure to audit or litigation. In practice, a tax position is useful only if it can be explained simply, supported by documents and defended before ANAF or a court.

1) General consultancy and risk review

A tax-risk review is not merely a check of returns. It means identifying areas where ANAF may ask questions: deductibility, VAT, related-party transactions, payments to non-residents, service invoices, cash, stock, employee benefits, management fees, intra-group contracts or operations with suppliers considered problematic by the tax authority.

• analysis of current tax obligations and risk areas
• review of documentation: contracts, invoicing, flows, receipts, payments and deliveries
• compliance plan and defence file for recurring situations
• preparation of commercial explanations before the audit, not after the report
• identification of missing documents or documents that must be completed lawfully and consistently
• alignment of the tax position with commercial, accounting and, where relevant, criminal risks

2) VAT: deduction, refunds, adjustments and cross-border operations

VAT is one of the areas where audits quickly become technical and evidence-heavy. Denial of deduction or refund is not countered by general statements, but by proof of transaction reality: contracts, orders, deliveries, receipts, transport documents, correspondence, payments, economic explanations and traceability. In cross-border operations, the place of supply, person liable for payment, reverse-charge treatment, possible fixed establishment and refund procedure must also be checked.

For this area, see VAT audits in Romania: refunds, adjustments and denied input VAT and the article VAT refunds and cross-border transactions: disputes with ANAF for foreign companies.

• correct qualification of operations, rates, exemptions and reverse charge
• input VAT deduction, denial of deduction, adjustments, pro-rata and delayed or refused refunds
• intra-Community transactions and economic-substance risks
• imports, exports, transport documents and proof of delivery
• special situations: restructurings, M&A, transfers of assets and reorganisations
• non-resident companies, VAT registration, fixed establishment and refund procedures

3) International tax law

In cross-border files, the tax problem does not stop at Romanian law. Double-tax treaties, tax residence, withholding tax, payments to non-residents, documents accepted in practice, tax-residence certificates and the group’s explanation of commercial flows must be checked. An international structure may be perfectly legitimate, but hard to defend if the documents do not show economic substance and transaction logic.

For foreign companies active in Romania, see Tax issues for foreign companies in Romania: VAT, registration and risks. For a practical perspective on cross-border transfers, see Cross-border transfers of assets and ANAF scrutiny.

• tax residence for individuals and legal entities
• double-tax treaties and tax-residence certificates
• withholding tax on dividends, interest, royalties and services
• cross-border structures and documents accepted in practice by the authorities
• preparation of the position for foreign shareholders, directors or investors
• coordination of the Romanian tax position with the group position in other jurisdictions

4) Transfer pricing

In transfer pricing, the legal position must be supported by economic analysis and documents. It is not enough to have an intra-group contract. Functions, assets, risks, service benefit, method selection, comparables, margins, payments and the link between contract and operational reality must be shown. During audits, ANAF may challenge margins, interest, management services, cost-sharing, intangibles or adjustment mechanisms.

For this topic, see Transfer pricing in Romania: TP file, ANAF adjustments, proof and experts.

• analysis of intra-group transactions and adjustment risks
• transfer-pricing documentation and argumentation during audits
• strategy if ANAF challenges margins, methods or comparables
• preparation of proof of performance and benefit for intra-group services
• coordination with economic experts for benchmarking and comparables
• planning where there is double-taxation risk or cross-border procedures

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ANAF audits: preparation, assistance and risk management

A tax audit should not be treated as simple administrative correspondence. Answers given during the audit may become the basis of the inspection report, assessment decision, administrative challenge, court case and, sometimes, a criminal complaint. Each response must therefore be verifiable, coherent and supported by documents. It matters who replies, what is sent, in which format, how proof of communication is preserved and what explanations are given for sensitive transactions.

For an overview, see ANAF tax inspection: what inspectors check, what your rights are and how to prepare.

1) Before the audit: when prevention is still possible

Before the audit, you can still control the order, documents and explanations. This is the stage where risk can be reviewed, missing documents identified, the internal point of contact established and coherent explanations prepared for sensitive areas. The point is not to fabricate a defence, but to organise real evidence and economic context.

• mapping sensitive areas and risky flows: VAT, deductibility, related-party transactions, non-residents
• preparing key documents and coherent explanations
• communication plan: who responds, how, in what format and with which evidence
• checking contracts, invoices, receipts, deliveries, payments and correspondence
• preparing the defence file for recurring operations
• early identification of tax-criminal risk

2) During the audit

During the audit, two extremes should be avoided: total passivity and impulsive replies. If you do not respond, inspectors may draw conclusions from the absence of documents. If you respond too quickly, without verification, you may create contradictions that are difficult to repair. Each answer should be preserved, dated, linked to the request and supported by clear annexes.

• written responses and management of document requests
• quick identification of the tax authority’s theories and response through evidence
• coordination with the accountant or tax consultant for consistency
• organisation of documents by transaction, period, partner and topic
• review of minutes and documents retained or copied by inspectors
• careful positioning where there are indicators of criminal referral

3) After the audit: report, decision and measures

After the audit, the review must begin with the acts issued and their communication. The inspection report, assessment decision, annexes, minutes, internal references and correspondence must be read together. Not every error is decisive, but some procedural defects, ignored evidence, unsupported conclusions or calculation errors can matter in the administrative challenge and in court.

• analysis of the report and acts issued, including procedural defects
• challenge strategy: administrative appeal, suspension, court litigation, in the correct order
• protection plan in enforcement: garnishments, guarantees and enforcement challenge
• checking interest, penalties and calculation base
• preparation of a tax or accounting expert report where necessary
• alignment of the tax position with possible criminal or contraventional risk

4) DGAF and anti-fraud controls

DGAF controls can move faster and may involve sensitive evidence. Inspectors may request explanations, documents, stock records, information about cash, suppliers, deliveries or invoices. The risk is not only tax-related. There may be contraventional risk, confiscation, complementary measures or escalation toward criminal proceedings. The reaction must be fast, but not improvised.

See the dedicated page DGAF anti-fraud controls: response strategy and evidence protection.

• identifying the scope of the control and documents requested
• creating an internal information circuit so responses are not contradictory
• protecting useful evidence and tracking documents handed over or copied
• analysing tax, contraventional and criminal risks
• preparing a later challenge or defence if needed

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Tax challenges and litigation: from ANAF act to court

1) Administrative challenge against ANAF acts

In many tax files, the administrative challenge is the moment when the ground is set for everything that follows. A good challenge is clear, documented and drafted with the court stage in mind: from reasoning to relevant annexes and the order of arguments. It is not enough to say that ANAF was wrong. You must show where, through which act, against which evidence and with what effect on the assessed amount.

For the dedicated page, see Romanian tax dispute: challenging ANAF assessment decisions and audit reports. For the blog guide, see Challenging ANAF tax assessment decisions and other tax acts.

• file audit: decision, report, annexes, minutes, requests, responses and SPV or postal communications
• chronological reconstruction: what ANAF requested, what you sent, what it recorded and what it ignored
• identification of illegality and lack of factual basis
• annexing relevant documents in an order that is easy to follow
• preparing court arguments from the administrative stage
• coordination with suspension or enforcement where effects are urgent

2) Court litigation: annulment, suspension and damages

Tax litigation in court is not a simple repetition of the administrative challenge. The court must receive a structured position, with documents, expert reports, economic explanations and clear legal arguments. Depending on the file, the discussion may concern annulment of the decision, cancellation of accessories, suspension of enforcement, compensation, refund of amounts paid or effects on tax records.

For suspension, see the article Suspension of enforcement of administrative and tax acts in court.

• court actions to annul assessment decisions and related acts
• suspension requests where effects must be stopped quickly
• evidence strategy: accounting or tax expert reports, documents, hearings and interrogatories
• proof of a well-grounded case and imminent damage in suspension requests
• management of security and documents needed to show practical impact
• compensation where there is a legal basis and evidence

3) Tax enforcement: garnishments, notices and seizures

Bank account garnishment and tax enforcement are often the most painful part. In practice, it is essential to identify quickly what can be challenged, which measures can be limited, which amounts are real, which amounts have already been paid or offset, what guarantees exist and how ongoing activity can be maintained. A challenge on the merits does not automatically solve cash-flow blockage; sometimes the merits, suspension and enforcement must be managed at the same time.

For the dedicated page, see Romanian tax enforcement: account freezes, notices and seizures. For the blog guide, see Bank account garnishment and tax enforcement by ANAF.

• analysis of the notice, enforcement title, garnishment, seizure and enforcement file
• checking amounts, accessories, offsets, payments and limitation where relevant
• challenge to enforcement and urgent requests to limit effects
• strategy regarding guarantees, instalment plans, mediation or partial payment without losing defences
• operational-continuity plan: salaries, suppliers, current taxes and critical contracts
• coordination with the merits litigation if the tax act is being challenged

4) Tax precautionary measures: seizure and preventive garnishment

Tax precautionary measures may appear before the merits dispute is clarified. They can freeze bank accounts, stock, equipment or other assets important for current activity. The defence is not identical to the defence on the tax obligation: here, the legal basis, reasoning of risk, proportionality, link with the amount pursued and immediate operational impact matter.

See the dedicated page Challenging ANAF tax precautionary measures: seizure and preventive garnishment.

• identifying the act issued, competent body, date of service and practical effects
• checking reasoning and factual support for risk
• analysis of proportionality between the amount pursued and assets frozen
• documenting the effect on current activity
• separating the defence against the measure from the defence on the merits of the tax debt

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Tax-criminal overlap: when an ANAF audit can become a criminal file

Some tax audits remain strictly fiscal. Others may escalate toward criminal proceedings, especially when inspectors discuss allegedly fictitious invoices, deductions without substance, cash, interposed companies, suppliers with non-compliant tax behaviour, related-party transactions, possibly forged documents or large alleged losses. In such files, the tax defence and criminal defence must not undermine each other.

For the dedicated page, see Tax-criminal overlap: ANAF audit, criminal complaint risk and defence strategy. For related articles, see Criminal cases triggered by tax audits, Called in for questioning as a suspect after an ANAF tax audit and Ne bis in idem and tax evasion in Romania.

• identifying indicators that the file may escalate toward criminal proceedings
• protecting useful evidence and avoiding contradictory explanations
• coordinating the tax challenge with the right of defence in criminal matters
• preparing directors, CFOs and persons asked for explanations
• separating facts, documents and roles of each person involved
• strategy for seizures, confiscation, alleged damage and precautionary measures

Joint and several liability for company tax debts

Joint and several liability is one of the most sensitive procedures for directors, former directors, shareholders or other persons whom ANAF seeks to make personally liable for company tax debts. The problem is not only the amount. The problem is the transfer of the tax debt from the company to the individual, with risk of personal enforcement, garnishment, seizure and direct personal consequences. In such files, it must be checked whether ANAF properly individualised the conduct, whether there is a link between facts and damage, whether the deadline is respected and whether the evidence supports the authority’s conclusion.

For the dedicated page, see Joint and several liability for company tax debts: challenge strategy. For the blog article, see Joint and several liability of company directors for tax debts.

• analysis of the ANAF decision and conduct alleged
• separation between company liability and individual liability
• chronology review: management, audit, enforcement, insolvency, dissolution, transfers
• challenge of insufficient evidence or generic reasoning
• defence against personal enforcement if measures have already started

Compliance notices, desk audits and personal tax situation checks

Not every tax problem begins with a classic inspection. Sometimes you receive a compliance notice, a document request, a desk audit or a notice of verification regarding your personal tax situation. These stages may look less aggressive than an assessment decision, but they can prepare the ground for large amounts. The response must be handled carefully: what you explain, which documents you send, what cannot yet be supported and how you avoid letting a rushed clarification be used against you.

For individuals, ANAF may compare declared income with acquisitions, transfers, bank accounts, loans, gifts, foreign income, crypto, rent, dividends or other sources. In such situations, the issue is not only tax-related: if the differences are large and explanations are not coherent, criminal risk may also arise. A chronology of income, assets, accounts and supporting documents should be prepared.

For individuals, see You received a compliance notice or notice of verification regarding your personal tax situation. For companies, the same logic applies to desk audits, thematic controls or specific requests: responses must be complete, but not speculative, and supported by documents.

• analysis of the notice and response deadline
• identification of documents supporting the explanations
• separation of certain facts from interpretations or estimates
• preparation of a coherent response with ordered annexes
• assessment of whether the compliance stage may lead to an assessment decision or extended audit
• coordination of the tax position with criminal risk where differences or explanations are sensitive

Foreign companies, non-resident investors and international groups

For foreign companies working in Romania, tax analysis is not limited to whether there is taxable profit. Tax registration, VAT, fixed establishment, withholding tax, residence documents, double-tax treaties, representation before ANAF, exchange of information between jurisdictions and the risk that a cross-border structure is seen as artificial or lacking substance must be checked.

A foreign investor may receive a Romanian tax assessment without immediately understanding the practical effect: frozen local accounts, impact on Romanian assets, group-level questions, auditors’ concerns, financing difficulties or reputational risk. In these files, documents must be prepared so that they are understandable to the Romanian authority, while remaining compatible with the group’s position in other jurisdictions.

See also Challenging an ANAF tax assessment as a foreign owner of a Romanian company. In practice, these files require a clear link between the Romanian tax act, group documents, local representation and any foreign procedures.

• tax registration and VAT for non-resident companies
• analysis of fixed establishment or permanent establishment risk
• withholding tax, residence certificates and tax treaties
• documents accepted in Romania: translations, apostilles, legalisations and representation
• VAT refunds for EU or non-EU companies
• coordination of the Romanian position with auditors, consultants and external legal teams

Tax irregularities and effects on public procurement, financing and commercial relations

A tax act does not affect only the relationship with ANAF. For companies, it may influence participation in public procurement, banking relations, financing lines, group reporting, audits, commercial partners and the ability to obtain tax certificates. Sometimes, the issue is not only the annulment of the act, but also the management of immediate effects on activity: certificates, accounts, reputation, contracts, guarantees and ongoing projects.

In public procurement, tax irregularities or criminal convictions may create additional risks. In some cases, a self-cleaning strategy, documentation of corrective measures and an explanation of how the operator remedied its situation may be needed. For context, see Exclusion from public procurement after criminal convictions, tax irregularities or conflicts of interest.

• analysis of the effect of the tax act on tax certificates and participation in tenders
• coordination of the tax challenge with communication to banks, auditors or partners
• documentation of corrective measures where there is exclusion or termination risk
• strategy for preserving critical operations during litigation
• checking the impact on directors, shareholders and the group

What you receive after the first review

After the first document-based review, the goal is not a generic answer, but a working route. Depending on the file, this may include the deadlines running, acts that can be challenged, enforcement risks, prospects of suspension, missing documents, weak points in the ANAF report, useful evidence, criminal risk, communication steps and foreseeable costs. In many cases, the main value of the first review is not reacting incorrectly.

For example, in a VAT case, the first review should show whether the problem is formal, evidentiary or about economic substance. In an enforcement case, it must be checked whether the amount pursued is correct, whether the acts were served, whether payments or offsets exist and what impact the garnishment has on activity. In a tax-criminal file, it must be assessed which documents can be used without creating contradictions and which persons must be prepared for possible questioning.

This way of working helps control costs. Instead of collecting documents without order, drafting long replies without proof or starting litigation without a clear objective, we establish the order of steps and the usefulness of each action. Sometimes a good chronology and a well-structured set of annexes are worth more than dozens of pages of general explanations.

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Typical situations where it makes sense to talk

• you received a tax inspection notice or you are already under audit
• you received repeated document requests and do not know what to send
• you received an inspection report or assessment decision and the next step is unclear
• you have a bank account garnishment, enforcement notice, enforcement title or seizure
• ANAF refuses deductions, VAT refunds or challenges transaction reality
• you received a joint and several liability decision as director, former director or shareholder
• you are a foreign investor, company or shareholder with tax issues in Romania
• there is a tax-evasion criminal-risk issue based on audit findings
• ANAF challenges transfer pricing, margins or intra-group services
• you need suspension of the fiscal act to avoid operational blockage
• you received a compliance notice or notice of verification of your personal tax situation

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How we work, step by step

1. Initial discussion and objective. We clarify what you received, what is urgent, which deadline is running and what result you need: annulment, suspension, unblocking, refund, risk reduction or coordinated defence.
2. Document audit. We review ANAF acts, correspondence, report, decision, accounting records, contracts, invoices, payments, annexes and proof of service.
3. Chronology. We establish the order of events: requests, responses, audits, acts, communications, garnishments, payments, offsets and deadlines.
4. Strategy and calendar. We choose the correct steps: administrative route, suspension, court, enforcement, guarantees, expert reports and criminal strategy if needed.
5. Evidence. We determine which evidence is decisive and how it will be used: documents, expert reports, correspondence, commercial explanations, registers and interrogatories.
6. Drafting and representation. We prepare responses, administrative challenges, suspension requests, court claims, enforcement challenges and procedural positions.
7. Implementation. We track the practical effect: amounts, accessories, accounts, garnishments, refunds, tax records, deletion of measures, enforcement or operational unblocking.

Documents useful for the first review

You do not need to send a disorganised file of hundreds of pages. For the first review, the key acts, proof of service and a chronology are useful. After the main documents are reviewed, a targeted list of missing documents can be prepared.

Document	Why it matters	Notes
Notice, ANAF/DGAF requests, report, decision, minutes	They show the scope of the audit, acts issued and deadlines	Send the full set, including annexes
Proof of service: SPV, post, email, minutes	It determines the challenge or court deadline	The service date is essential
Contracts, invoices, statements, payments, delivery and transport documents	They prove transaction reality	Group them by partner, period and transaction
Correspondence with partners and commercial explanations	They show economic logic and transaction context	Include emails, orders, reports and minutes
Internal policies, procedures, registers, internal notes	They help prove substance and traceability	Useful in VAT, deductibility and intra-group transactions
Transfer pricing documentation	It supports related-party transactions	Include FAR, benchmarking, comparables and intra-group contracts
Enforcement acts: notice, title, garnishment, seizure	They show concrete measures and urgency	Needed for enforcement challenge or unblocking
Short chronology	It links documents to facts and shows gaps in the ANAF analysis	One or two pages are enough at the beginning

Common mistakes I help you avoid

• reflex responses during the audit, without strategy and without proof
• lack of a coherent narrative supported by documents
• late or incomplete challenge of tax acts
• sending documents chaotically, without index and without connection to the request
• ignoring tax enforcement until accounts are frozen
• artificially separating tax risk from criminal risk where clear indicators exist
• using commercial explanations that do not appear in contracts, invoices or payments
• neglecting accessories: interest, penalties, calculation periods and bases
• postponing expert evidence until the court case or procedure is already advanced
• assuming that payment automatically fixes all effects without checking the tax record
• signing positions or statements without checking the impact on directors or individuals involved

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Dedicated tax-law service pages

• Romanian tax dispute: challenging ANAF assessment decisions and audit reports
• VAT audits in Romania: refunds, adjustments and denied input VAT
• Romanian tax enforcement: account freezes, notices and seizures
• Challenging ANAF tax precautionary measures: seizure and preventive garnishment
• DGAF anti-fraud controls: response strategy and evidence protection
• Transfer pricing in Romania: TP file, ANAF adjustments, proof and experts
• Tax issues for foreign companies in Romania: VAT, registration and risks
• Joint and several liability for company tax debts: challenge strategy
• Tax-criminal overlap: ANAF audit, criminal complaint risk and defence strategy

Useful blog resources

Frequently asked questions

When does it make sense to involve a lawyer: before or after the audit?

Usually earlier. Preparation and audit management directly influence what is written in the report and what follows. Many problems are easier to handle if documents and explanations are organised correctly at the beginning, rather than reconstructed after the assessment decision is issued.

Can I quickly stop bank account garnishment?

It depends on the acts issued, the amount pursued, the enforcement stage and whether there is a ground to challenge or suspend the measures. There are steps that may limit effects or challenge the measures, but enforcement acts, proof of service and a rapid review of the tax file are needed.

If there is criminal risk, does it still make sense to challenge fiscally?

In many situations, yes, but the strategy must be coordinated. Files with two tracks, tax and criminal, are managed with the same logic: documents, evidence, chronology, clear roles and calculated decisions. A tax position should not be drafted without checking possible criminal impact.

What should I do if I received an assessment decision?

The first step is to identify the service date, challenge deadline, inspection report, annexes and assessed amounts. Then we reconstruct the audit chronology and check which documents were ignored, which calculations are questionable and which evidence must be attached to the administrative challenge.

Is the administrative challenge enough or do we need to go to court?

It depends on the authority’s decision and the file. The administrative challenge should be drafted so that it can also support the court stage if needed. In some cases, litigation is foreseeable from the beginning, especially when the amounts are large or ANAF’s interpretation of transactions is central.

Can you help if I am a foreign company or shareholder?

Yes. In cross-border files, the key is to prepare documents that can be used efficiently in Romania: before the authority, in court, with the bank or within the group. Incompatible positions between jurisdictions should be avoided and residence, VAT, withholding-tax and transfer-pricing documents should be clarified early.

Is expert evidence useful in a tax case?

It can be very useful, but not in every case. Expert evidence must be prepared through clear questions and ordered documents. In VAT, transfer pricing, deductibility, accessory calculations or complex flows, an expert report can clarify matters that the court cannot verify only from the parties’ statements.

What legal fee should I expect?

After the initial review, I propose a fee model: fixed, hourly, staged or complementary success fee where permitted. I explain what it includes and which collateral costs may appear: court fees, security, expert reports, translations, travel or enforcement costs.

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Let’s define the next steps quickly and clearly

Tell me what you received from ANAF or what is expected: tax inspection notice, document request, report, assessment decision, garnishment, enforcement notice, seizure, joint-liability decision, compliance notice or summons in a criminal file triggered by an audit. Mention the deadline and the current effect on activity. I will respond with concrete next steps and the short list of documents that matter.

E-mail: alexandru@maglas.ro | WhatsApp: message on WhatsApp

Official sources and legal references

The sources below are useful for checking the general legal framework. For a specific file, the applicable version of the law, documents in the file, date of service, deadlines and relevant practice must be checked.

• Law no. 207/2015 on the Fiscal Procedure Code, Romanian legislative portal
• Law no. 227/2015 on the Fiscal Code, Romanian legislative portal
• Law no. 554/2004 on administrative litigation, Romanian legislative portal
• Law no. 241/2005 on preventing and combating tax evasion, Romanian legislative portal
• Council Directive 2006/112/EC on the common system of value added tax, EUR-Lex
• Council Directive 2008/9/EC on VAT refunds to taxable persons established in another Member State, EUR-Lex

Note: the information on this page is general. In tax matters, details in documents and chronology can change the solution.