Law no. 177/2026 – cancellation of some VAT tax obligations and accessories

In the Official Gazette no. 700 of August 24, 2026, Law no. 177/2026 regarding the cancellation of certain tax obligations, which introduces an important facility for certain situations in which the tax authorities have additionally established VAT and accessories.

Mainly, the law provides:

• cancellation of differences in VAT and tax obligations accessories established by taxation decisions in certain situations of ex officio cancellation of registration for VAT purposes, for fiscal periods between January 1, 2019 and the date of entry into force of the law;
• certain VAT differences are also cancelled and accessories established for agricultural cooperatives, related to the purchase of agricultural machinery for which the right of deduction was exercised, for the period of January 9, 2024 – the date of entry into force of the law;
• obligations that are still in the tax records will be canceled ex officio by the fiscal body, by issuing a cancellation decision;
• if the respective obligations have already been paid, compensated or extinguished in another way, the amounts can be returned to the taxpayer, upon request. The limitation period for requesting restitution begins to run from the date of entry into force of the law;
• for the situations covered by the law, ANAF no longer issues new taxation decisions for the respective periods, and the decisions already issued, but not communicated to the taxpayer before the entry into force of the law, are no longer communicated, and the obligations will be removed from the tax records.

The concrete application procedure is to be approved by order of the ANAF president, within 30 days of the entry into force of the law.

Practical recommendation: companies that had their VAT code canceled ex officio and for which ANAF established VAT differences for periods starting in 2019 should check the taxation decisions and the payer sheet. In the case of obligations already paid, the possibility of formulating a request for restitution will have to be analyzed, after the publication of the ANAF procedure.