The end of the parliamentary summer vacation could not fail to cause a rapid change of the Fiscal Procedural Code this year, which contains both useful clarifications and a number of undesirable points, which in some cases will lead to an increase in disputes between taxpayers. and tax authorities. Since there has been no consistent and meaningful public debate about these changes, some of them, in our opinion, are extremely important from a practical point of view and deserve to be addressed now. after the fact. Therefore, we present some synthetic observations about them:

Useful explanations

The draft amendments to the Procedural Code (“draft OG”) introduces certain precise and desirable clarifications from a practical point of view, especially regarding the suspension of the statute of limitations for the right to establish tax liabilities in the event of the death of the taxpayer, regulation of interaction with the fiscal authority using electronic means of remote communication, which has already been used in practice, as well as clarification of the consequences of making a criminal notification regarding the current tax audit, i.e. limiting the termination of the audit only to tax obligations that are the subject of the notification.

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The article was signed by Dan Dascălu – partner lawyer at D&B David si Baias, coordinator of the litigation and labor law department and Mykhailo Boyan – partner lawyer at D&B David si Baias

Article supported by PwC Romania