Government Emergency Ordinance no. 132/2024, published in the Official Journal of Romania on 22 November 2024, introduces modifications to both the Fiscal Code and the Fiscal Procedure Code, regulating important aspects related to the deadlines for applying the fiscal amnesty set out under GEO 107/2024.

Hence, the deadline for submitting an application and paying the amounts necessary to obtain the fiscal amnesty has been extended to 19 December 2024 (the initial deadline was 25 November 2024). However, this new deadline does not apply to the notification concerning the intention to benefit from the cancellation of fiscal obligations, which should have been submitted by 25 November 2024.

Debtors who have submitted the notification by 25 November 2024, but do not request the cancellation of fiscal obligations by 19 December 2024 and meet all other conditions, will benefit from the cancellation of those fiscal obligations through the automatic issuance of a cancellation decision by the fiscal authorities. If the request for cancellation is submitted before the conditions are met, but these conditions are fulfilled by 19 December 2024, the fiscal authorities will issue the cancellation decision after verifying the conditions.

Debtors which did not submit the notification by 25 November 2024 (this was optional and intended to suspend enforcement actions) can still benefit from the facilities if they fully pay the amounts owed by 19 December 2024 and meet all other conditions.

Thus, the new regulations partially amend the initial deadlines set by GEO 107/2024 concerning the fiscal amnesty. However, the other provisions and procedural aspects remain applicable, as detailed extensively in our previous briefing, which you can access below. 

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