Changes were made to the Tax Procedure Code, the government adopted an emergency resolution on Wednesday. HotNews.ro also wrote about the project before its adoption, but it is not clear whether changes have taken place after about 70 measures, especially since the Chamber of Fiscal Consultants recently pointed out that there are even problems of logical inconsistency.

We are waiting for what will appear in the Official Gazette. Until then, we have a communiqué from the Government, which states that the changes concern:

• transmission of compliance notices by the tax inspection body to taxpayers/probable taxpayers who will be selected for tax audit, with the aim of re-analyzing the tax situation of individuals and possibly declaring and correcting tax returns, as an alternative method of risk management. This measure is aimed at encouraging voluntary compliance by taxpayers with income declaration, on the one hand, and on the other hand, it is bringing tax legislation into line with existing best practices at the international level;

• transmission by the competent authority, with a check of the personal financial situation, of voluntary compliance notices to natural persons who have a fiscal risk, similar to the notice of compliance in the fiscal inspection procedure;

• establishing another mechanism for voluntary compliance by taxpayers/taxpayers by notification by the fiscal authority at the request of the taxpayer/taxpayer of the class/subclass of risk to which the relevant taxpayer/taxpayer was assigned (this measure will be applied from January 1, 2026);

• in the case of checking the personal financial status of an individual, the risk analysis must be carried out by a structure at the level of the central apparatus of the State Public Administration;

• establishment of defining control elements specific to anti-fraud control activities carried out by tax anti-fraud control authorities, so that there is no confusion between different types of control and there is a single terminology at the level of the relevant legislation;

• centralization at the national level of risk analysis activities, as well as fiscal inspection activities, fiscal inspection bodies that have the competence to carry out fiscal inspection throughout the country, in the case of fiscal receivables, which is managed by a fiscal authority within the ANAF.

• introduction of the possibility for a taxpayer/tax payer to request the issuance of a preliminary tax ruling after the completion of half of the statutory period for conducting a tax audit (for example, after 90 days in the case of large taxpayers or 45 days in the case of medium taxpayers) in the event that he was not informed by the tax inspection body about the end of the tax period and the type of tax liability.

• a direct mention of the possibility of anti-fraud control bodies to carry out document checks throughout the country for symmetry with the powers to carry out fiscal checks throughout the country;

• clarification of the method of conducting documentary verification by introducing some rules that provide for the periods that can be subjected to documentary verification in accordance with the identified fiscal risk, the method of communication within the framework of the procedure, which will be carried out as a rule, using electronic means of remote transmission, as well as fiscal obligations that may be the subject of this procedure.

In fact, the project was written in ANAF, and then sent to the Ministry of Finance to be submitted to the Government meeting.

The government says these changes were necessary for the “Enforcement of the legislative framework concerning the scope of activities of fiscal control structures” phase of Romania’s National Recovery and Resilience Plan (PNRR), which is being implemented by ANAF.

In the draft version, we will also learn how ANAF will define bad faith and that the Fiscal Fraud Office will be able to apply sanctions in all areas of ANAF’s remit… As I said above, that remains to be seen. that appears in the official monitor these days.