Since 1 July 2024, any income ascertained by the tax authorities whose source has not been identified is taxed at a rate of 70%, compared with the 16% rate that applied previously. Late-payment interest (0.02% per day) and non-declaration penalties (0.08% per day) can be added on top of the tax rate, so the total obligations imposed on a taxpayer can easily exceed the entire amount considered unjustified. In practice, out of a wealth discrepancy that the tax authority classifies as “income of unidentified source,” the state can claim more than the full amount itself.<\/p>\n\n\n\n
According to data provided by ANAF (the National Tax Administration Agency) to the specialist press in the summer of 2026, over the past year and a half 467 tax assessment decisions have been issued applying the 70% rate, establishing additional tax of more than RON 426 million (over EUR 81 million), with the largest individual assessment exceeding RON 15 million. Moreover, under Order No. 768\/2026 of the ANAF President, in force since 6 July 2026, the power to establish the 70% tax has been extended to inspectors of the General Directorate for Tax Anti-Fraud, signaling an intensification of audits of individuals.<\/p>\n\n\n\n
The Brisc Legal team is currently assisting clients in such personal tax situation audits, including a case in which the tax authority is seeking to apply the 70% rate to income relating to 2018\u20132021, so the practical experience we have gained allows us to present in this material both the complete legal framework and the defenses that can be developed in this type of case.<\/p>\n\n\n\n
The taxation of income whose source has not been identified was introduced into Romanian law by Government Ordinance No. 30\/2011, which added Article 79\u00b9 to the old Fiscal Code (Law No. 571\/2003), applicable starting in 2012, together with the regulation of the personal tax situation audit procedure. The tax rate was 16%, applied to the adjusted taxable base, established through indirect methods of income reconstruction.<\/p>\n\n\n\n
This legislative solution was carried over into Article 117 of Law No. 227\/2015 on the Fiscal Code, in force since 1 January 2016, which, in the form applicable until 30 June 2024 inclusive, provided:<\/p>\n\n\n\n
“Any income ascertained by the tax authorities, under the conditions of the Tax Procedure Code, whose source has not been identified shall be taxed at a rate of 16% applied to the adjusted taxable base. Through the tax assessment decision, the tax authorities shall establish the amount of the tax and of the accessory obligations.”<\/em><\/p>\n\n\n\n Under Article III(13) of Law No. 296\/2023 on certain fiscal-budgetary measures to ensure Romania’s long-term financial sustainability (published in the Official Gazette No. 977 of 27 October 2023), Article 117 of the Fiscal Code was amended and now reads as follows:<\/p>\n\n\n\n “Any income ascertained by the tax authorities, under the conditions of the Tax Procedure Code, whose source has not been identified, shall be taxed at a rate of 70% applied to the adjusted taxable base. Through the tax assessment decision, the tax authorities shall establish the amount of the tax and of the accessory obligations.”<\/em><\/p>\n\n\n\n The temporal application of this amendment was expressly regulated by Article VII(1)(b) of Law No. 296\/2023, according to which:<\/p>\n\n\n\n “the provisions of point 13 enter into force as of 1 July 2024 and apply to tax assessment decisions issued by the tax authorities as of that same date.”<\/em><\/p>\n\n\n\n In summary, the evolution of the tax rate is as follows:<\/p>\n\n\n\n It is essential to note that, throughout the entire period from 2012 to 30 June 2024, the law provided for a 16% rate. The central question is whether the 70% rate can be applied to income earned before 1 July 2024<\/em>, for the sole reason that the tax assessment decision is issued after that date. We will show below that the courts’ answer is no.<\/p>\n\n\n\n The tax provided for by Article 117 of the Fiscal Code can only be established at the end of a regulated administrative procedure: the personal tax situation audit (PTSA), provided for by Articles 138\u2013147 of Law No. 207\/2015 on the Tax Procedure Code, or, in certain cases, within a documentary audit. Knowing each stage is essential, because each stage generates rights for the taxpayer and obligations for the tax authority, the breach of which can later be relied on in defense.<\/p>\n\n\n\n Under Article 138(2) of the Tax Procedure Code, the audit is preceded by a risk analysis carried out at the level of ANAF’s central apparatus. Non-compliance risk exists when a difference is found between the income estimated by the tax authority and the income declared by the individual that is greater than 10% of the declared income, but no less than RON 50,000<\/strong>. Both thresholds must be met cumulatively.<\/p>\n\n\n\n Individuals identified as tax-risk cases receive, under Article 140\u00b9 of the Tax Procedure Code, a compliance notice, informing them that, within 30 days, they may reassess their tax situation and file or correct their tax returns. After that deadline, individuals with a high tax risk who have not remedied the risks are automatically subject to a personal tax situation audit or a documentary audit.<\/p>\n\n\n\n Under Article 138(3) of the Tax Procedure Code, competence to carry out the personal tax situation audit is established by order of the ANAF President, with the central apparatus having competence over the entire national territory. Under ANAF President’s Order No. 2,778\/2020, competence belongs to:<\/p>\n\n\n\n An important practical consequence, often surprising for taxpayers: competence is national, not territorial<\/strong>. A taxpayer residing in Cluj County may, entirely lawfully, be audited by the tax audit service of the DGRFP Ia\u0219i \u2014 a situation we have encountered in our recent practice. The tax assessment decision is issued by the tax authority that carried out the audit, based on the audit report.<\/p>\n\n\n\n As of 6 July 2026, under ANAF President’s Order No. 768\/2026, which amended OPANAF No. 2,778\/2020, the power to establish the tax on income from unidentified sources was also extended to the General Directorate for Tax Anti-Fraud, a circumstance that will increase the number of such procedures.<\/p>\n\n\n\n The audit itself follows, in essence, the following steps:<\/p>\n\n\n\n At the end of the audit, the tax authority presents the individual with its findings and their tax consequences (Article 145(3) of the Tax Procedure Code), giving the individual the opportunity to state a position in writing. The outcome of the audit is recorded in the audit report, which forms the basis of the tax assessment decision or, if the taxable base is not adjusted, of the decision to close the procedure (Articles 145\u2013146). The tax assessment decision constitutes a tax claim title and becomes enforceable under the law, which is why a swift response after it is communicated is essential.<\/p>\n\n\n\n In all procedures concluded after 1 July 2024, the practice of the competent tax authorities is uniform: they apply the 70% rate to all tax assessment decisions issued after that date, regardless of the fact that the audited period is earlier<\/strong> \u2014 often, indeed, many years earlier (2017\u20132021). The tax authorities rely on the wording of Article VII(1)(b) of Law No. 296\/2023 \u2014 “applies to tax assessment decisions issued by the tax authorities as of that same date” \u2014 and argue that the tax is owed “under the old law,” with the new law merely changing the rate, for the future, by reference to the moment the decision is issued.<\/p>\n\n\n\n The practical consequence is dramatic: taxpayers audited for periods when the law provided for 16% receive tax assessment decisions at 70%, solely because the audit \u2014 whose duration does not depend on them \u2014 concluded after 1 July 2024. In cases handled by our team, we have even encountered a situation where the audit was initiated in 2024 for the years 2018\u20132021, and the findings were communicated only in 2026, applying the 70% rate to income allegedly earned 5\u20138 years before the new rate came into force. This practice was already criticized by industry professionals at the time the law was adopted, who pointed out that two taxpayers in identical situations end up being taxed differently (16% or 70%) solely depending on how quickly the audit authority acts.<\/p>\n\n\n\n At the administrative stage, the tax authorities do not abandon this interpretation: challenges based on non-retroactivity are systematically rejected, with the dispute-resolution structure applying ANAF’s own practice.<\/p>\n\n\n\n Law No. 296\/2023 was subject to a priori constitutional review. By Decision No. 523 of 18 October 2023 (published in the Official Gazette No. 974 of 26 October 2023), the Constitutional Court rejected the objection of unconstitutionality. On a superficial reading, one might think that the retroactivity issue was settled in favor of the tax authority. The reality is exactly the opposite, and the key lies in the reasoning of the decision.<\/p>\n\n\n\n The authors of the referral argued (para. 27 of the decision) that immediately taxing unjustified income at 70%, “including for periods prior to the entry into force of the amendment to the Fiscal Code,” raises issues from the perspective of the principle of non-retroactivity of tax law and the principle of non-discrimination. Responding to these criticisms, the Court held, in paragraph 203 \u2014 a finding that can today influence the outcome of hundreds of cases:<\/p>\n\n\n\n “With regard to the criticisms made against Article III(13) (referring to Article 117) of the law, the Court finds them unfounded in relation to the criticisms raised, the challenged text merely amending the percentage at which income ascertained by the tax authorities whose source has not been identified is taxed. The Court also notes that the challenged text does not provide for what the authors of the objection indicate \u2014 for periods prior to the entry into force of this amendment, so that, in reality, the criticism raised concerns the interpretation and application of the law.” (CCR Decision No. 523\/2023, para. 203)<\/em><\/p>\n\n\n\n In other words, the objection was rejected precisely because, in the Constitutional Court’s interpretation, the text does not provide for periods prior to the entry into force of the amendment<\/strong>. The law is constitutional because it does not operate retroactively; if the tax authorities nonetheless apply it to income relating to periods before 1 July 2024, that is a matter of misinterpretation and misapplication of the law, which can be censured by the courts.<\/p>\n\n\n\n The first landmark judicial ruling on the issue came from the Suceava Court of Appeal \u2014 Administrative and Fiscal Litigation Section. By Judgment No. 87 of 13 June 2025, the court annulled a tax assessment decision issued following a personal tax situation audit (audited period 2017\u20132021), by which the tax authority had applied the 70% rate to income of unidentified source, as well as the decision resolving the administrative challenge.<\/p>\n\n\n\n Relying precisely on paragraph 203 of CCR Decision No. 523\/2023, the Suceava Court of Appeal held that the three findings made by the Constitutional Court “converge toward the conclusion that the legal rule does not apply to the tax period prior to its entry into force” and that, consequently:<\/p>\n\n\n\n “the applicable legal provisions were those of Article 117 of the Fiscal Code in the form in force for the period subject to the tax audit, provisions under which any income ascertained by the tax authorities, under the conditions of the Tax Procedure Code, whose source has not been identified is taxed at a rate of 16% applied to the adjusted taxable base” (Suceava Court of Appeal, Judgment No. 87\/13.06.2025)<\/em><\/p>\n\n\n\n The court went further and examined the harm caused: the erroneous application of the 70% rate had also deprived the taxpayer of the real possibility of accessing the tax amnesty facilities in force (under Emergency Ordinance No. 107\/2024), so that the harm could only be remedied by annulling the administrative acts.<\/p>\n\n\n\n The ruling was essentially confirmed, definitively, by the supreme court. By Decision No. 2750 of 3 June 2026<\/strong>, the High Court of Cassation and Justice \u2014 Administrative and Fiscal Litigation Section \u2014 allowed the appeals on points of law, partially quashed the judgment, and, on retrial, partially allowed the taxpayer’s action, partially annulling the tax assessment decision and the decision resolving the administrative challenge:<\/p>\n\n\n\n “exclusively with respect to the additional tax obligations exceeding the tax obligations calculated by applying the 16% tax rate to the adjusted taxable base” (High Court of Cassation and Justice, Decision No. 2750\/03.06.2026, case No. 641\/39\/2024)<\/em><\/p>\n\n\n\n The supreme court’s ruling is unequivocal: income relating to periods before 1 July 2024 is subject to the 16% rate, not the 70% rate<\/strong>. The new law applies exclusively for the future.<\/p>\n\n\n\n We note that the same line of reasoning was applied by the Suceava Court of Appeal in the matter of suspending enforcement as well: by a judgment issued on 23 February 2026, the court suspended enforcement of a tax assessment decision exceeding RON 8 million, issued through the retroactive application of the 70% rate, holding that the manner in which Article 117 of the Fiscal Code had been applied raised a serious doubt as to the lawfulness of the act (details in Section IX).<\/p>\n\n\n\n An effective defense in a procedure based on Article 117 of the Fiscal Code can be built on several fronts. From our experience, the following defenses can be developed: the statute of limitations (which eliminates time-barred years entirely), the non-retroactivity of the rate (which reduces the tax from 70% to 16% for periods before 1 July 2024), substantive defenses regarding the source of the funds (which reduce or eliminate the taxable base), and procedural irregularities (which can lead to the nullity of the acts and strengthen the overall defense).<\/p>\n\n\n\n Under Article 110(1) and (2) of the Tax Procedure Code, the tax authority’s right to establish tax claims is time-barred after 5 years, running from 1 July of the year following the one for which the tax obligation is owed. The tax claim arises at the moment the taxable base is constituted (Article 21 of the Tax Procedure Code) \u2014 that is, at the moment the income is earned, not at the moment it is “ascertained” by the tax authority.<\/p>\n\n\n\n In applying this defense, two matters must be carefully checked against the case file:<\/p>\n\n\n\n Note, however, certain particularities: suspensions arising from the COVID state of emergency\/alert (Article XIII of Emergency Ordinance No. 48\/2020) and extension periods granted at the taxpayer’s request must be checked case by case and may shift the deadlines.<\/p>\n\n\n\n This argument was detailed in Sections V and VI above. In summary, the defense rests on: Article 15(2) of the Constitution (the law applies only for the future); Article 6(2) of the Civil Code, applicable in tax matters via Article 3(2) of the Tax Procedure Code (legal facts occurring before the new law’s entry into force cannot generate legal effects other than those provided for by the law in force at the time they occurred); the principle of certainty and predictability of taxation (Article 3(b) and Article 4 of the Fiscal Code); the rule of in dubio contra fiscum (Article 13(6) of the Tax Procedure Code); the generally binding finding in paragraph 203 of CCR Decision No. 523\/2023; and the final ruling of the High Court in Decision No. 2750\/03.06.2026. In addition, the 70% rate combined with accessory obligations can exceed 100% of the income, taking on a confiscatory character, contrary to Article 1 of Protocol No. 1 to the ECHR and Articles 44 and 56(2) of the Constitution.<\/p>\n\n\n\n Every irregularity must be documented and relied upon. Examples we have actually encountered and that can be invoked:<\/p>\n\n\n\n The only defense that attacks the taxable base itself is proof of the source of the funds: loans received from family members or third parties, repayment of amounts previously credited to the taxpayer’s own companies, sales of goods, gifts (including wedding gifts), damages, and savings built up before the audited period. A loan is not income \u2014 the amount received enters the estate together with the obligation to repay it (Article 2158 of the Civil Code) and is not among the categories of taxable income listed in Article 61 of the Fiscal Code; symmetrically, the repayment of a loan granted does not enrich the lender’s estate.<\/p>\n\n\n\n The practice of the tax authorities and the courts is, however, demanding when it comes to proving these sources: private documents without a certified date, transfers made exclusively in cash, and family ties all feed suspicions of insincerity. For this reason, the evidentiary file must be built professionally: notarized statements from the lenders regarding the reality of the loan and the origin of the funds, proof of the lenders’ financial standing (bank statements, income, sales of assets), correlation of each loan with the immediate use of the funds, purchase and resale invoices for goods sold, as well as tax expert evidence on the flows.<\/p>\n\n\n\n A personal tax situation audit should not be managed “at the end,” once the tax assessment decision has already been issued, but from the very first act \u2014 ideally, from the compliance notice itself. Specifically, the assistance we provide to clients covers:<\/p>\n\n\n\n An administrative challenge does not suspend enforcement of the tax assessment decision (Article 278(1) of the Tax Procedure Code). The decision becomes enforceable, and the tax authority may commence enforcement \u2014 garnishment of bank accounts, seizures, and sale of assets \u2014 even while the administrative challenge and, later, the court proceedings are ongoing. This is why the request to suspend enforcement, based on Article 14 or Article 15 of Administrative Litigation Law No. 554\/2004, is just as important as the merits.<\/p>\n\n\n\n The court may order suspension of enforcement if two conditions under Article 14(1) of Law No. 554\/2004 are cumulatively met:<\/p>\n\n\n\n Suspension may be requested either under Article 14 (after filing the administrative challenge with the tax authority, before bringing the annulment action \u2014 with effects lasting until the ruling on the merits) or under Article 15 (together with the main action, or separately, until it is resolved \u2014 with effects lasting until the case is finally resolved). Where suspension is obtained under Article 14, the annulment action must be brought within 60 days of communication of the decision resolving the administrative challenge, on pain of the suspension automatically ceasing (Article 278(5) of the Tax Procedure Code).<\/p>\n\n\n\n For tax administrative acts, suspension is conditional on lodging a security deposit, calculated under Article 278(2) of the Tax Procedure Code, by reference to the amount contested:<\/p>\n\n\n\n The security deposit is lodged with CEC Bank at the court’s disposal and is returned at the end of the litigation, as provided by law; it is not a payment, but a guarantee.<\/p>\n\n\n\n The well-justified case.<\/strong> In cases where the 70% rate was applied to income relating to periods before 1 July 2024, the main argument will be the retroactive application of the tax law: simply comparing the audited period (stated in the tax assessment decision itself) with the date the increased rate came into force reveals, prima facie, without any examination of the merits, a serious doubt as to the lawfulness of the act. Exactly this reasoning was validated by the Suceava Court of Appeal in its judgment of 23 February 2026: the court held that applying the new tax law to legal relationships arising before its entry into force, given that non-retroactivity is a constitutional principle (Article 15(2)) and that Article 6(2) of the Civil Code prohibits attaching other legal effects to completed facts, “raises a serious doubt as to the lawfulness of the tax administrative act, falling within the well-justified case,” and the court also noted that CCR Decision No. 523\/2023 (para. 203) supports the taxpayer’s allegations. This argument can, where applicable, be reinforced by other indications of unlawfulness visible on the face of the matter: expiry of the limitation period before the act was issued, a flagrant overrun of the statutory audit duration, failure to state reasons for the act, or complete disregard of the evidence submitted.<\/p>\n\n\n\n Imminent damage.<\/strong> This is argued by reference to the amount of the obligations established relative to the taxpayer’s actual assets and income: the impossibility of paying by the due date makes enforcement foreseeable; garnishment of bank accounts seriously and immediately affects daily living and, for entrepreneurs, the financing of their companies; forced sale of real estate is irreversible \u2014 a property sold under enforcement cannot be recovered in kind, and the sale is typically made below market price, harm that could not be fully repaired even if enforcement were later reversed following annulment of the decision. In its judgment of 23 February 2026, the Suceava Court of Appeal held exactly these circumstances: the particularly onerous nature of the obligations, the serious and immediate impact on daily living, and the irreversible nature of forced real-estate enforcement. We recommend supporting this condition with concrete evidence: a list of assets, land register extracts, proof of current income, and the status of financial commitments.<\/p>\n\n\n\n Effects of suspension.<\/strong> For as long as the court-ordered suspension lasts, all effects of the act are suspended, the obligations are not entered in the tax clearance certificate, and no late-payment or non-declaration penalties are owed (Article 278(3) and (4) of the Tax Procedure Code). The suspension ruling is enforceable by law but may be appealed within 5 days of communication.<\/p>\n\n\n\n If the administrative challenge is rejected (or is not resolved within 6 months \u2014 in which case Article 281(5) of the Tax Procedure Code allows direct recourse to the courts), the next step is the administrative litigation action, seeking annulment of the decision resolving the administrative challenge, the tax assessment decision, and the audit report, with discharge from the obligations established.<\/p>\n\n\n\n The time limit for bringing this action is 6 months from communication of the decision resolving the administrative challenge (Article 11 of Law No. 554\/2004, Article 281 of the Tax Procedure Code), or 60 days where suspension under Article 14 was previously obtained (Article 278(5) of the Tax Procedure Code). Competence lies with the tribunal for tax obligations up to RON 3,000,000, and with the court of appeal for larger amounts (Article 10 of Law No. 554\/2004), with the first-instance ruling subject to an appeal on points of law \u2014 to the court of appeal, or to the High Court of Cassation and Justice, respectively.<\/p>\n\n\n\n The distinctive feature of this action: it is the only stage at which a complete body of evidence on the merits is taken \u2014 judicial tax expert evidence on the indirect method applied (opening balance, net flows, calculation errors), new documents, and witnesses to prove the factual circumstances of the loans. The court examines both lawfulness (competence, procedure, statement of reasons, application of the law over time) and the merits of the tax assessment decision, and the grounds of unlawfulness are not limited to those raised in the administrative challenge.<\/p>\n\n\n\n The 70% taxation of income of unidentified source is, at present, one of the most aggressive instruments available to the tax administration \u2014 but also one of the most legally vulnerable when applied retroactively or in breach of procedure. CCR Decision No. 523\/2023 (para. 203) and the final case law of the High Court of Cassation and Justice (Decision No. 2750\/03.06.2026, confirming the Suceava Court of Appeal’s ruling) outline the solution to the central problem: the new law applies exclusively for the future, and income relating to periods before 1 July 2024 is subject to the 16% rate. Added to this are defenses with major impact \u2014 the statute of limitations, which can eliminate entire years from the assessment, and other potential defenses: the maximum audit duration, the right to be heard, the obligation to establish the initial wealth position, and the rigor of the indirect methods.<\/p>\n\n\n\n The Brisc Legal<\/strong> team assists individuals undergoing personal tax situation audits at every stage described in this material: from the compliance notice and the audit notice, to the position statement on the findings, the administrative challenge, the suspension of enforcement of the tax assessment decision, and the annulment action, including before the High Court of Cassation and Justice.<\/p>\n\n\n\n If you have received a compliance notice, an audit notice, a communication of findings, or a tax assessment decision based on Article 117 of the Fiscal Code, time is working against you \u2014 the 30, 45, and 60-day deadlines are short, and the documents filed during the administrative procedure determine the success of the entire process.<\/p>\n\n\n\n We encourage you to contact us for a review of your situation: horatiu@brisc.ro<\/strong> | www.brisc.ro<\/strong> | Cluj-Napoca, Calea Doroban\u021bilor no. 14\u201316, Cluj City Center, 2nd floor.<\/p>\n\n\n\n This material is for informational purposes only and does not constitute legal advice. Each tax situation has particularities that can significantly change the defense strategy.<\/em><\/p>\n","protected":false},"excerpt":{"rendered":" I. Why This Matters. Context and Stakes Since 1 July 2024, any income ascertained by the tax authorities whose source has not been identified is taxed at a rate of 70%, compared with the 16% rate that applied previously. Late-payment interest (0.02% per day) and non-declaration penalties (0.08% per day) can be added on top … <\/p>\nPeriod<\/strong><\/th> Rate<\/strong><\/th> Legal Basis<\/strong><\/th><\/tr><\/thead> 2012 \u2013 31.12.2015<\/td> 16%<\/td> Article 79\u00b9 of Law No. 571\/2003, introduced by GO No. 30\/2011<\/td><\/tr> 01.01.2016 \u2013 30.06.2024<\/td> 16%<\/td> Article 117 of Law No. 227\/2015, original form<\/td><\/tr> From 01.07.2024<\/td> 70%<\/td> Article 117 of the Fiscal Code, amended by Article III(13) of Law No. 296\/2023; applicable to tax assessment decisions issued as of 01.07.2024 (Article VII(1)(b))<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n III. The Personal Tax Situation Audit Procedure<\/h2>\n\n\n\n
1. Preliminary Activities: Risk Analysis and the Compliance Notice<\/h3>\n\n\n\n
2. Competence to Conduct the Audit and Issue the Tax Assessment Decision<\/h3>\n\n\n\n
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3. Conducting the Audit: The Notice, the Wealth Statement, Indirect Methods, Maximum Duration<\/h3>\n\n\n\n
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4. Concluding the Audit: Findings, the Taxpayer’s Position, the Report and the Tax Assessment Decision<\/h3>\n\n\n\n
IV. Practice of the Tax Authorities: The 70% Rate Applied to Periods Before 1 July 2024<\/h2>\n\n\n\n
V. Constitutional Court Decision No. 523\/2023<\/h2>\n\n\n\n
VI. Recent Case Law: Suceava Court of Appeal, Definitively Confirmed by the High Court \u2014 the New Law Applies Only for the Future<\/h2>\n\n\n\n
VII. Defenses Available to the Taxpayer Under Audit<\/h2>\n\n\n\n
1. Statute of Limitations on the Tax Authority’s Right to Establish Tax Claims<\/h3>\n\n\n\n
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2. Non-Retroactivity of the 70% Rate<\/h3>\n\n\n\n
3. Procedural Irregularities and Tax Authority Errors \u2014 Concrete Examples<\/h3>\n\n\n\n
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4. Substantive Defenses: Justifying the Source of the Funds<\/h3>\n\n\n\n
VIII. The Lawyer’s Steps, Stage by Stage<\/h2>\n\n\n\n
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IX. Suspending Enforcement of the Tax Assessment Decision (Law No. 554\/2004)<\/h2>\n\n\n\n
1. Conditions for Suspension<\/h3>\n\n\n\n
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2. The Security Deposit (Cau\u021biune)<\/h3>\n\n\n\n
Amount Contested<\/strong><\/th> Security Deposit<\/strong><\/th><\/tr><\/thead> Up to RON 10,000<\/td> 10% of the amount<\/td><\/tr> RON 10,000 \u2013 100,000<\/td> RON 1,000 + 5% of the amount exceeding RON 10,000<\/td><\/tr> RON 100,000 \u2013 1,000,000<\/td> RON 5,500 + 1% of the amount exceeding RON 100,000<\/td><\/tr> Over RON 1,000,000<\/td> RON 14,500 + 0.1% of the amount exceeding RON 1,000,000<\/td><\/tr> Non-monetary claims<\/td> RON 1,000<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n 3. How the Conditions Are Argued, in Practice, in Article 117 Fiscal Code Cases<\/h3>\n\n\n\n
X. The Action to Annul the Tax Assessment Decision<\/h2>\n\n\n\n
XI. Conclusions. Why Specialized Assistance Matters<\/h2>\n\n\n\n