- Romania’s ANAF Order No. 1123/2026 amends the VAT refund procedure under Order No. 352/2022, keeping the basic process unchanged but significantly broadening risk screening for undue VAT refunds.
- The new rules apply to VAT returns for August 2026 and Q3 2026, as well as returns already being processed, except those already sent for post-refund tax inspection settlement.
- New taxpayer-level risk indicators include adverse status of shareholders/associates/directors or related entities, frequent material error corrections, sharp refund increases, late filing of D394/D390/D406, insolvency-related proceedings, company age under six months, and mismatches with RO e-Invoice/RO e-Cash Register data.
- Supplier risk is now relevant where key invoice issuers show risk indicators such as inclusion in refund-risk databases, insolvency/bankruptcy/liquidation, tax offences, filing noncompliance, VAT debts, data mismatches, inactive/cancelled VAT status, or recent incorporation/VAT registration.
- Related-party supplies are also flagged: a refund risk exists if at least one key supplier is affiliated with the taxpayer claiming the VAT refund.
Source: tpa-group.ro
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.
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