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The tax administration has announced the completion of the first phase of implementing the law on conditional forgiveness of unpaid tax liabilities.
The tax administration has announced that over 22 thousand other taxpayers have benefited from the process, with 60 million euros in liabilities erased/cancelled.
Meanwhile, the automatic deletion process continues in the second phase for taxpayers who will benefit from forgiveness of up to 25% of their obligations for the period 2015-2019 for payments made within December 2026.
Following instruction no. 11, dated 14.05.2026 "On the implementation of law no. 86/2025 "On the cancellation, extinguishment and payment of tax liabilities to the central and local tax administration and duties payable to customs", the Tax Administration informs all taxpayers that, within 20 days from the entry into force of this instruction, a complete list of entities that benefit from the cancellation of tax liabilities, as well as those that do not benefit, will be compiled.
Only taxpayers who do not benefit from the deletion or extinguishment of unpaid tax liabilities will be notified electronically through the "e-Filing" system.
After completing the process of drafting and notifying the lists, the Tax Administration will continue with the automatic compensation of the VAT credit balance or other taxes with the tax obligations of the entities.
Categories of liabilities that benefit from deletion/extinguishment
Tax liabilities until December 31, 2014
Unpaid tax liabilities pertaining to tax periods up to 31.12.2014 are completely erased, including fines and late interest. The principal liability for social security and health insurance contributions is not forgiven.
Tax liabilities for the period January 1, 2015 – December 31, 2019
-50% of the principal obligation is canceled, if the remaining 50% is paid at once from 10.06.2026 to 30.06.2026;
-25% of the principal obligation is waived if the remaining 75% is paid from 10.06.2026 to 31.12.2026. In both cases, fines and late payment interest are completely waived.
In both cases, fines and late payment interest are completely waived.
Tax liabilities for the period January 1, 2020 – December 31, 2024
Fines and late fees are waived provided that the tax for the relevant period is paid in full (100% of the principal) from 10.06.2026 to 31.12.2026.
Other benefits provided by law
According to Law No. 86/2025:
Obligations for entities deregistered in the Central Bank or by court decision until 31.12.2024 are deleted, except for social security and health contributions;
Fines for non-declaration or late declaration of declarations pertaining to the periods up to 31.12.2024 are waived, provided that the undelivered declarations are submitted by 30.06.2026;
Fines for late submission of financial statements and the decision on the allocation of the result, calculated until 31.12.2024, are deleted;
Fines and interests generated by payroll changes as a result of legal/sub-legal acts with retroactive effect or final court decisions are hidden.
Administrative fines are waived for periods until 31.12.2024.
Entities that do not benefit
Entities that do not benefit from the cancellation/extinguishment of obligations:
Have been convicted by a final court decision for criminal offenses in the tax and/or customs field;
Are under judicial proceedings or investigation for tax and/or customs criminal offenses during the period of law enforcement;
They have a final court decision in favor of the Tax or Customs Administration for the obligations subject to the benefit.
Taxpayers who are in the process of administrative or judicial appeal may benefit from the provisions of the law only if they waive the administrative appeal or the right to sue, appeal or recourse, according to legal provisions. The presentation of the act by the subject will be carried out upon official request to the relevant Regional Tax Directorate, starting from 10.06.2026 before the payment of the principal obligation, but no later than 30.11.2026.
The Tax Administration invites all taxpayers to verify their financial situation in the "e-Filing" system and make payments according to the published deadlines, in order to benefit from the facilities provided for in the law./ Monitor
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