- Romania has significantly broadened the risk indicators used to assess whether a VAT refund claim may be undue, applying to VAT returns for September 2026 and Q3 2026 onward.
- New risk factors include the taxpayer’s shareholders/directors and related entities, frequent corrections or unusually large increases in refund claims, late filing of D394/D390/D406, insolvency-related status, recent incorporation (under six months), and mismatches between VAT returns and RO e-Invoice/RO e-Cash Register data.
- Risk is also deemed present if a supplier generating a significant share of deductible VAT has circumstances indicating tax risk, such as being listed in risk databases, insolvency/bankruptcy/liquidation, tax-record offenses, filing failures, outstanding VAT debts, inactive/cancelled VAT status, recent incorporation or VAT registration, or using a tax period other than the calendar month.
- The prior rule treating affiliation between a supplier and the refund claimant as a risk factor has been removed.
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.













