From the compliance notice (notificare de conformare) to the tax assessment decision (decizie de impunere) and its administrative appeal (contestație): the tax inspection procedure, explained in the order in which you encounter it.
By the time you receive a notice, your file has already gone through a risk analysis, a set of automatically reported data and, often, a compliance notice that many read as a mere formality. The moment you learn that you are being reviewed is, almost always, a moment at which some of the decisions have already been made without you.
This section brings together the analyses on the tax inspection procedure: the classic tax inspection, the unannounced control, the anti-fraud control and the review of personal tax affairs. It is not a theoretical account of the Tax Procedure Code, but a practical reading of it: what triggers a control, what time limits run from each communication, what you may justifiably refuse, what happens when a document is missing, and at what point a discussion about money changes in nature and becomes a criminal file.
It is aimed at company directors and at people who actually run a business, at PFA holders and the liberal professions, but also at individuals with no connection to any company, because the review of personal tax affairs does not require a company to exist, only a difference between what you declared and what the administration sees. It is also useful to accountants and lawyers assisting a client through a control who need the procedural markers in a form they can check.
The material is organised chronologically, in the order in which the issues actually arise. Before the control brings together the signals that precede a review and the window in which you can still act cheaply. The control under way deals with conduct during the review: communication, documents, the lawful duration and the last real window for influencing the outcome, the position statement on the draft report. After the control covers the tax assessment decision and what can be done with it, the limitation period, the tax authority coming back to the same period, and the threshold into criminal law. The review of individuals groups the analyses on personal wealth: the 70% tax on income from an unidentified source, crypto, foreign accounts reported through CRS, cash and bank transfers, and the line between occasional and economic activity.
One point of delimitation: the administrative procedure stops here. What follows once the administrative appeal has been rejected, the actual court case against ANAF, is covered in the tax litigation section, and the criminal consequences in the economic criminal law section.
The signals that precede a review, and the window in which you can still act cheaply.
18 September 2026
The other end of the reporting chain, with obligations far heavier than the seller's. Who is a reporting platform operator and who falls outside it, the four categories of relevant activity, the due-diligence procedures that begin a year in advance and are built into the product rather than the return, the mandatory mechanism for closing the account or withholding payment after two warnings, the 31 January deadline, and the penalties of 20,000 to 100,000 lei, with revocation of registration and the app access being cut off.
18 September 2026
Three separate obligations, with different debtors: the national logistics tax of 25 lei per parcel, from January 2026, owed by the supplier or the platform and collected by the courier, not the recipient; the transitional customs duty of 3 euro per tariff heading, from July, following the removal of the EU exemption; and VAT owed in Romania from the first leu. How these stack up on an ordinary parcel, why a small import becomes a tax problem for a company supplied through personal orders, and the seven things to establish.
18 September 2026
An invoice validated in the system, with its index and signature, cannot be deleted or changed: it is reversed by a new document, with negative values and a reference to the original invoice, and reissued, under Article 330 of the Tax Code, each document carrying its own five-working-day deadline. An invoice rejected at validation is corrected and resubmitted, but the deadline runs from the original issue date. The typical cases, from the wrong amount to the wrong client, an invoice wrongly received as the beneficiary, how it is reflected in the VAT return and SAF-T, and the seven steps.
18 September 2026
The e-TVA compliance notice was abolished in two steps, by OUG nr. 89/2025 on 1 January and OUG nr. 13/2026 on 9 March, but the four data flows remain and are compared in the general risk analysis. What each one reports, e-Factura, SAF-T, the VAT return and Declaratia 394, where they legitimately differ and where the difference is dangerous, the SAF-T deadlines and fines, compulsory for everyone from 2026, and the seven-step reconciliation to do before the inspector does it for you.
18 September 2026
Two changes in opposite directions in 2026: persons invoicing under their personal numerical code were exempted from 1 June by Legea nr. 88/2026, before the obligation announced in January took effect, while the deadline for everyone else was shortened to five working days. PFA, individual enterprises and the liberal professions holding a tax code remain fully bound, B2B since 2024 and B2C since 2025, irrespective of VAT status. The two-question test, the penalties, including the invoice that ceases to be a supporting document, and the seven steps.
18 September 2026
Goods from personal property are sold free of tax under Article 62(m). Buying in order to resell is an economic activity. Platforms report under DAC7 those sellers with more than 30 transactions or more than EUR 2,000, and couriers report cash-on-delivery sums; these are reporting thresholds, not taxing thresholds. How ANAF tells a wardrobe from a shop, what the compliance notice means, and the seven steps, with or without one.
18 September 2026
From 2026 the host's regime turns on a single number: up to 7 rooms, counted across all properties, the income is income from the use of property (cedarea folosinței bunurilor), with a 30% flat-rate deduction, that is 7% of gross; above 7 rooms it is an independent activity, with different contributions. The platform's commission does not form part of the income, the occupancy record is compulsory according to the ANAF guidance, short-term accommodation is not VAT exempt in the way ordinary letting is, and the platforms report under DAC7. The seven steps.
18 September 2026
The question
18 September 2026
The comparisons written for 2024 no longer hold: dividends are taxed at 16%, the micro threshold is 100,000 euros, and CASS for a PFA can rise to 72 minimum wages. The three layers of taxation, correctly compared at three income levels, why the SRL only wins below the micro threshold and with reinvested profit, what the calculation leaves out, liability, reclassification and administration, and the seven questions that decide it.
18 September 2026
Since 2024 there have been two calculation bases and they are not added to each other. Independent activities owe CASS on actual net income, between 6 and 72 minimum wages, the upper cap having been raised in 2026. Rent, dividends, investments and the other income under Article 155(c) to (h) are aggregated with each other, in bands of 6, 12 and 24 minimum wages, but not with PFA income. The 2026 figures, the employee with additional income, CAS for the self-employed, optional cover, and the seven calculation steps.
18 September 2026
The 16% rate, under Article 97(7) as amended by Legea nr. 141/2025, applies according to the date of the distribution resolution, not of payment; a resolution from December 2025 stays at 10%. CASS is owed in tiers of 6, 12 and 24 minimum wages, aggregated with the shareholder's other income, through the Declaratia unica. Interim dividends and how they are adjusted, the six-month payment deadline, the company's Declaratia 100 and Declaratia 205, and the seven steps to take before a distribution.
18 September 2026
What decides the matter is not the number of sales but continuity and the conduct of a trader. The implementing rules exclude the personal home and inherited goods, but treat more than one supply a year of other goods as an economic activity, and the CJEU, in Słaby and Kuć, settled the criterion of active steps to market the property. How reclassification appears in ANAF decisions, including for second-hand cars, why VAT and income tax operate on separate planes, and the seven steps.
18 September 2026
Since 1 September 2025, under OG nr. 22/2025, the exemption threshold is 395,000 lei, and registration must be requested no later than the day the threshold is exceeded, with VAT applying from the transaction that exceeds it, not from the first of the following month. The old 10-day rule was repealed, but it is still widely quoted. How turnover is calculated under Article 310(2), what ANAF does ex officio, and why tax established retroactively comes out of your margin, the seven steps.
18 September 2026
A plan meeting the definition in Article 7(39) of the Tax Code, including the minimum period of one year between grant and exercise, is taxed neither on grant nor on vesting, but only on sale, as investment income, on the whole appreciation from a nil base. A plan that does not meet it, with vesting under a year or settled in cash, is salary, with contributions. The four conditions, the three moments and the seven steps, including the account with the foreign broker.
18 September 2026
Output tax becomes chargeable on receipt, but input deduction is likewise deferred until payment, both for you and for your clients, which is why large buyers tend to avoid suppliers on this scheme. The threshold raised to 5,000,000 lei from 1 March 2026, the transitional regime, entry through Form 097, mandatory exit and exit by choice, and the calculation, based on receipt and payment terms, that decides whether it pays off.
18 September 2026
The threshold has been lowered to 100,000 euros, checked on 31 December 2025 and aggregated with related enterprises. The 3% rate is gone, only 1% remains, but the eligibility conditions remain cumulative: an employee or a paid director, consultancy revenue under 20%, only one microintreprindere per shareholder. Moving to corporate income tax takes effect from the quarter in which the breach occurs and is final. The 6.25% margin that decides between micro and profit tax, and the seven steps.
18 September 2026
Classification decides everything: an independent activity for any channel carried on with continuity, copyright income for works assigned, other sources only for an isolated collaboration. Products received are income in kind, payments from platforms established in other Member States require the special VAT code, and the platforms report under DAC7. What ANAF has already checked, and the seven steps, including regularising the past.
18 September 2026
The special tax on high-value assets tripled on 1 January 2026, from 0.3% to 0.9%. It is due on residential buildings worth more than 2,500,000 lei, by individuals only, and on cars worth more than 375,000 lei, by individuals and companies alike, in each case only on the excess above the threshold. Two separate deadlines, 30 April and 31 December, the updated Form 216, and what ANAF does ex officio when you do not file.
17 July 2026
The compliance notice is the first official sign that ANAF has placed you in a risk analysis. It is not yet a control, but the 30-day time limit that runs from communication can decide the fate of the whole file. What it is, what you risk by ignoring it, and the first seven concrete steps.
17 July 2026
A phone call does not establish any obligation and does not start any time limit, but what you say can end up in a note you cannot challenge. How to check whether the call is genuine, how to recognise “ANAF Antifrauda” vishing, and why the rule stays the same: everything in writing.
17 July 2026
The notice starts a clock: 15 days, or 30 for large taxpayers. What it must contain, how to ask for a postponement, why it differs radically from the notice for a review of personal tax affairs, and the seven-step plan for the interval before the first day.
17 July 2026
Requested as part of the review of personal tax affairs, the wealth statement becomes the centrepiece of the file. The 60 and 15-day deadlines, a fine of up to 50,000 lei, the criminal risk of a false statement, and the road to the 70% tax on unexplained amounts.
Conduct during the review: what is asked for, what is handed over, how long it can last, and where you can still step in.
17 July 2026
The unannounced control and the anti-fraud control both take place with no prior notice, and what decides the fate of the file is not written in the law: conduct in the first hours. The inspectors' identification, what they can and cannot ask for, taking documents with an inventory, the mistakes that turn a control into a criminal file, and the position statement within 5 working days.
17 July 2026
A tax inspection is rarely lost at the final discussion: it is lost along the way, in an explanatory note written in haste or in a stack of documents handed over with no inventory. The three rules of conduct that keep the file under control, and the mistakes that move a discussion about money onto criminal ground.
17 July 2026
The basis for these requests is Article 64 of the Tax Procedure Code, and the consequences of missing documents are precise: an estimated tax base, the burden of proof turned against you, fines and, in serious scenarios, a criminal file. The retention periods, lawful reconstruction, and when you may justifiably refuse.
17 July 2026
Exceeding the 180/90/45-day limits does not, by itself, void anything, but exceeding double that duration brings the inspection to an automatic end and voids any acts issued afterwards, along with the loss of the suspensive effect on the limitation period. The rules on suspension, the 270 days for individuals, and the steps to take when a control drags on.
17 July 2026
The draft inspection report is the last window in which you can still influence the outcome of the control, before it becomes a tax assessment decision. You have 5 working days (7 for large taxpayers) to file your position statement, and the tax authority must respond to it with reasons in the report.
The tax assessment decision and what can be done with it, including when the discussion changes in nature.
17 July 2026
The tax assessment decision brings a sum impossible to pay, and four time limits start running at once from communication. The road map for the first 45 days: the three strategic routes (payment under reservation, court-ordered suspension and a payment schedule in its 2026 form), with the price of each.
17 July 2026
The administrative appeal is filed within 45 days of communication, but it does not stop enforcement. How to give proper reasons for it, how to obtain suspension in court and what security it requires, when a payment schedule helps, and what role the party-appointed tax expert report plays.
17 July 2026
A tax inspection is carried out only once for each type of claim and each period. Coming back is the exception: a re-inspection requires real “additional data”, and a reopening stays strictly within the limits of the decision setting the assessment aside; both can be challenged.
17 July 2026
The 5-year period runs from 1 July of the following year, and the extended 10-year period requires a final criminal judgment, not a mere suspicion. How it is calculated, what interrupts it, what suspends it, and how to raise it, step by step.
17 July 2026
A control record sent to the prosecutor's office moves the discussion from money to liberty. The duty to report under Article 132 of the Tax Procedure Code, the distinction between error and intent, the signs that a control is changing in nature, and the non-punishment window under Legea nr. 126/2024.
Personal wealth under scrutiny: sources of funds, bank flows and the line between occasional and economic activity.
17 July 2026
ANAF President's Order no. 768/2026, in force since 6 July 2026, gives anti-fraud inspectors the power to carry out the review of personal tax affairs directly and to issue tax assessment decisions. What has changed, who is at risk, and the stages at which you can still defend yourself.
17 July 2026
From 2026 crypto gains are taxed at 16%, and the platforms report transactions directly to ANAF (DAC8). How the tax and CASS are calculated, how to reconstruct your transaction history, and how to avoid treatment as unexplained income taxed at 70%.
17 July 2026
Banks, brokers and fintechs in more than 100 jurisdictions report the balances and income of Romanian residents to ANAF every year. What the tax authority actually sees through CRS, what you declare in the Declaratia unica, how the foreign tax credit works, and what to do if you have received the notice about foreign income.
17 July 2026
The thresholds of Legea nr. 70/2015 as it stands in 2026, the two channels through which banks report (ONPCSB and Article 61 of the Tax Procedure Code), how loans and gifts are properly documented, and why a perfectly lawful deposit can become income taxed at 70%.
17 July 2026
Between July 2025 and May 2026 ANAF carried out 1,102 inspections of individuals, establishing additional liabilities of over 540 million lei. Where the line runs between occasional and economic activity, what obligations arise beyond it, the VAT threshold of 395,000 lei, and the compliance file that protects you retrospectively.
17 July 2026
If it fails to meet 4 of the 7 statutory criteria of independence, a PFA arrangement can be reclassified retrospectively as an employment relationship, with salary tax, CAS, CASS and penalties going back up to 5 years. Who is being targeted, what it costs, and how the defence is built.
Informative material, updated on 18 July 2026. It does not constitute legal or tax advice; individual situations must be assessed on their own facts.
The 156 analyses are grouped into four areas. A real case usually passes through several of them.
Taking ANAF to court: the action for annulment, suspension of enforcement, the evidence, the appeal on points of law and the recovery of sums paid.
12 analysesTax evasion, embezzlement, money laundering and the related economic offences: from the figure in the report to the defence in the file.
30 analysesTax residence, double taxation treaties, foreign income and assets, exit tax and DAC6 reporting.
17 analysesEconomic substance, jurisdictions and anti-abuse rules: what remains lawful after BEPS, ATAD and CRS, and where the line into criminal liability is crossed.
10 analysesSeparating personal wealth from business risk: principles, liability, the instruments that actually protect, and the line between lawful planning and fraud.
10 analysesTrusts and the Romanian fiducie, family foundations, international succession and forced heirship: how wealth is transferred lawfully between generations.
7 analysesParty-appointed and out-of-court tax expertise: the technical challenge to the loss calculation in an inspection, in litigation and in the criminal file, from objections to counter-expertise.
20 analysesThe file and the methods, the comparability study, ANAF adjustments to the median, intra-group services and loans, APAs and the inspection, for transactions between related companies.
11 analysesThe complete list of the 156 analyses published, in chronological order, with filters by area.
Go to InsightsTime limits run from the moment of communication, and most of them cannot be reinstated. A first conversation clarifies what is being alleged, what you need to substantiate, and what can still be influenced, before an estimate becomes an enforceable title (titlu executoriu).