Practical guide · Tax inspection · Worksheets

Worksheets for a tax inspection.

Five tools to fill in or print: the checklist for the first conversation, the communication identification sheet, the register of requests and documents handed over, the questions for the consultation and the table of time limits. Each sheet starts on a new page when printed.

Current version: https://fhtaxlaw.ro/en/fise-control-fiscal · version 1.0 of 16 October 2026

Sheet 1

Checklist for the first conversation.

Tick what you have. You do not need to have everything; the list shows what is missing.

Sheet 2

The communication identification sheet.

Fill it in with the document in front of you. The answers tell you which procedure it is and which time limit may be running; the chapter in the guide tells you what comes next.

QuestionWhere to find the answerYour answer
Who issued the document?the letterhead: the ANAF structure (county tax office, regional directorate, Anti-Fraud Directorate (Antifrauda), DGAMC (the large taxpayers directorate), etc.) 
What is the document called?the title below the letterhead: notification (notificare), notice (aviz), request (solicitare), draft report (proiect de raport), decision (decizie), payment demand (somație) 
Whom does it concern?the addressee: the individual (CNP, personal numeric code), the PFA (authorised self-employed individual) or the company (CIF, tax identification number) 
Under which article?the first paragraph; usually an article of the Tax Procedure Code 
What number and what date does it bear?the registration number and the date of issue 
When and how did you receive it?SPV (the date of the message), post (the date on the acknowledgement of receipt), hand delivery (the date of the signature) 
Which periods and which taxes are mentioned?the body of the document 
What are you asked for, and by when?the body of the document: documents, returns, attendance in person, reply 
Which remedy or which right is mentioned?the end of the document: administrative appeal, time limit, competent body 

The date of issue is not the same as the date of communication. Time limits run, as a rule, from communication. The explanation is in the chapter ANAF communications in SPV.

Sheet 3

Register of requests and documents handed over.

One row for each request received during the inspection. At the end of the inspection, the register shows what was requested, what was handed over, when and in what form. Keep it together with the copies of the documents handed over and the signed document lists (opisuri).

No.Date of the requestHow it was received (in writing, verbally, e-mail)What was requestedTime limit grantedWhat was handed over (document list)Date of handover and proofWho repliedRemarks
1
2
3
4
5
6
7
8
What I check
  • verbal requests are confirmed in writing, by a short e-mail or when the reply is handed over: “Further to the request dated..., we send you...”;
  • each handover has a document list: the list of documents, the number of pages, the signature of receipt or the electronic confirmation;
  • the version handed over is the version kept: if a document is corrected, the new version is handed over with the statement “replaces the document handed over on...”.
Sheet 4

Questions for the consultation.

Write them down beforehand. A good consultation answers all of them, even if some of the answers are “it cannot be known yet”.

  1. Which procedure is this and what can result from it?
  2. Which time limit is running now, from what date, and what happens if I miss it?
  3. Which documents am I missing and how can I obtain or reconstruct them lawfully?
  4. What must I answer in writing and what must I not state verbally?
  5. What role does the accountant have and what role do you have?
  6. What are the exposure scenarios, broadly, and what do they depend on?
  7. Is there a risk that the procedure moves into criminal territory? What increases it?
  8. What can I do about liquidity if an amount to pay results?
  9. What comes after the consultation and what would each stage cost?
Sheet 5

Table of time limits.

The table does not calculate the time limit for you. It shows which time limit exists, from which event it runs, which exceptions change it and where it is laid down. The exact date is established on the basis of the document received.

Time limitDurationEvent from which it runsExceptions and qualificationsLegal basis
Compliance after a compliance notice30 dayscommunication of the compliance noticecorrection does not rule out later selection; unremedied high risk leads mandatorily to an inspectionArt. 1211, 1401 of the Tax Procedure Code (TPC)
Interval between the notice and the start of the inspection15 days; 30 for large taxpayerscommunication of the notice of tax inspectionnotice communicated at the start of the inspection in five cases; the time limit can be waived; postponement once only, for justified reasonsArt. 122(2)-(5) TPC
Correcting returns before the inspectionuntil the start datecommunication of the notice of tax inspectionreturns filed after the start, for the periods under inspection, are not taken into accountArt. 122(7)(e), Art. 105(8) TPC
Maximum duration of the inspection45 days; 90 (medium-sized taxpayers); 180 (large taxpayers, secondary establishments, non-residents)the start dateexcluding periods of suspension; if double the duration is exceeded, the inspection terminatesArt. 126 TPC
Suspension of the inspectionat most 6 months; at the taxpayer's request, at most 3 monthsthe suspension decisionexceptions to the 6-month cap; the decision can be challengedArt. 127 TPC
Final discussionat least 3 working days; 5 for large taxpayerscommunication of the draft inspection reportthe taxpayer may waive the discussionArt. 130(2)-(4) TPC
Written position in the inspection5 working days; 7 for large taxpayerscompletion of the inspection (date of the final discussion or of the waiver)extension with the agreement of the head of the inspectionArt. 130(5) TPC
Issue of the decision after the inspectionat most 25 working dayscompletion of the inspection-Art. 131 TPC
Documents and explanations in a desk review30 dayscommunication of the notification (înștiințare)extension for good reasonsArt. 149(1)-(2) TPC
Written position in a desk review5 working days (+ at most 5)the hearingthe decision, within at most 25 working days of the hearingArt. 149(6) TPC
Documents requested in a review of personal tax status60 days, on pain of forfeiturecommunication of the notice of reviewa single extension of 30 daysArt. 138(6) TPC
Duration of the review of personal tax statusat most 270 daysthe start dateexcluding the periods granted for documentsArt. 140(6) TPC
Written position after an unannounced or anti-fraud inspection5 working daysto be checked on the official report (Art. 135, Art. 1371 TPC)-Art. 135, 1371 TPC
Option for videoconference2 working days, on pain of forfeiturethe information message in SPVthe option can no longer be changedANAF President's Order No 705/2026
Payment of the differences in the decisionby the 5th or the 20th of the following monthcommunication of the decision (between the 1st-15th or the 16th-31st of the month, respectively)-Art. 156(1) TPC
Administrative appeal45 days, on pain of forfeiturecommunication of the decision3 months if the decision does not state the remedy, the time limit and the competent bodyArt. 270 TPC
Oral presentation of the appealrequest within at most 30 daysregistration of the appealon pain of forfeitureArt. 276 TPC
Referral to the court if the appeal is not resolvedafter 6 monthsfiling of the appealextensions and periods of suspension are not countedArt. 281(5) TPC
Action in administrative court proceedings6 monthscommunication of the decision resolving the appealfor good reasons, at most one yearArticle 11(1)(a) and (2) of Law No 554/2004
Maintaining a suspension obtained before proceedingsthe action for annulment must be brought within 60 dayscommunication of the decision resolving the appealotherwise the suspension ceases by operation of lawArt. 278(5) TPC
Payment or mediation after a payment demand15 dayscommunication of the payment demandnotice of the intention to mediate stops enforcement from startingArt. 230, 2301 TPC
Appeal against enforcement15 days, on pain of forfeiturethe date on which you became aware of the enforcement actfiled with the courtArt. 260-261 TPC
Limitation period for the right to assess tax obligations5 years; 10 years for criminal offences sanctioned by a final judgment1 July of the year following the year for which the obligation is owed; for the 10-year period, the date on which the offence was committed (Art. 110(4))grounds for interruption and suspension, including the duration of the inspectionArt. 110-111 TPC

Time limits expressed in days are calculated under the Civil Procedure Code, unless the tax legislation provides otherwise (Article 75 of the Tax Procedure Code); those expressed in working days follow their own rule. Do not use the table as an automatic calculation tool: the date of communication and the exceptions must be checked on each document.

Informational material, updated on 16 October 2026. It does not constitute legal or tax advice; individual situations must be analysed case by case.

Contact

Has the review started?

Requests for documents, explanatory notes and replies remain on the file. Assistance in the procedure means keeping a record of requests, written replies and preparing the written position within the time limit.

What helps to have to hand: the notice, the requests received and the replies given, the signed official reports.

The initial message does not create a mandate and is not a consultation. Do not send documents through the form; I will ask you for them after the first contact, through an appropriate channel.

E-mailrolegal@pm.me
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