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Tax Law

What to Do When You Receive a Tax Demand from ANAF

Ioana Popescu 12 April 2026

Strict deadlines, challenge options, and when a challenge suspends enforcement. Mistakes to avoid when receiving a fiscal administrative act.

First step: read the document and record the receipt date

Deadlines run from the date of receipt (delivery) of the act. Every day counts.

Critical deadlines

  • 45 days for an administrative challenge (filed with the issuing tax authority)
  • 6 months for an action before the administrative court (after the challenge decision)

How to challenge

  1. Legal analysis (checking procedural and substantive legality)
  2. Drafting grounds (which rules were breached)
  3. Filing with supporting evidence
  4. Monitoring deadlines

Suspension of enforcement

A challenge does NOT automatically suspend payment. To obtain suspension: separate application + security (50% of the amount or a bond).

Recommendation

Consult a tax lawyer within the first 3–5 days of receipt. Chances of success increase significantly with early procedural analysis.

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