- ANAF Order No. 1,123/2026 amends the VAT refund procedure, adding a formal list of 14 tax risk indicators that can trigger an audit before VAT is refunded.
- If a taxpayer meets at least one risk criterion, ANAF may place it in a VAT refund risk database, suspend automatic/expedited approval, and send the case to tax audit; reimbursement will then depend on audit findings.
- The risk indicators cover, among others, shareholders/directors already in risk databases, prior liability/criminal acts in the tax record, large VAT adjustments or refund increases, repeated corrections, and late filing of D394/D390/D406 returns.
- Additional triggers include insolvency or insolvency-prevention status, businesses operating for less than 6 months, and material mismatches between VAT reported through RO e-Factura/RO e-Case de marcat and the refund claim.
- The new rules apply to VAT refund requests for August 2026 and Q3 2026, as well as requests already under review.
Source: teaha.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.
