Through Law 177/2026 on the cancellation of certain fiscal obligations, published in Official Gazette no. 700 of August 24, 2026, a series of fiscal amnesty measures are introduced, targeting certain value-added tax debts established by the fiscal authorities in specific situations.
What does it stipulate?
The law retroactively cancels certain principal fiscal debts representing VAT and related accessory obligations (penalties, interest). The measure applies in two distinct situations. The first targets companies whose VAT registration was canceled for reasons such as non-submission of tax returns or declaration of fiscal inactivity. For these companies, debts established by the Tax Authority through tax assessment decisions for fiscal periods between January 1, 2019, and the date the law came into force are canceled.
The second beneficiary category consists of agricultural cooperatives. For these, VAT differences and related accessories, established by the fiscal authority as a result of exercising the right to deduct tax for agricultural machinery acquisitions, are canceled. The fiscal period targeted in this case is shorter, specifically between January 9, 2024, and the date the law came into force.
An important aspect is that amounts already paid by taxpayers for debts canceled by this law can be recovered. The law explicitly stipulates that fiscal obligations extinguished by any means (payment, offsetting, etc.) are to be reimbursed upon the taxpayer’s request. The statute of limitations for requesting reimbursement begins to run from the date the law comes into force, offering companies a new window of opportunity to recover funds.
The cancellation of fiscal obligations will be carried out ex officio by the fiscal authority, by issuing a cancellation decision. Furthermore, the law prohibits fiscal authorities from issuing new tax assessment decisions for the types of debts and periods targeted. However, there is an important exception: the amnesty does not apply if the company distinctly recorded VAT in invoices or effectively collected the tax from clients, and this fact was ascertained by the authorities.
To whom does it apply?
The measures apply specifically to the following categories of taxpayers:
- Companies (taxable persons) whose VAT code was canceled between January 1, 2019 – August 24, 2026, for reasons expressly provided by the Fiscal Code (e.g., non-submission of tax returns for 6 consecutive months, registration in the Register of inactive/reactivated taxpayers, etc.) and who received tax assessment decisions for VAT and related accessories for this period.
- Agricultural cooperatives established according to specific legislation, which received tax assessment decisions to reimburse VAT deducted for the acquisition of agricultural machinery between January 9, 2024 – August 24, 2026.
What should you do?
- Check if the fiscal authority has issued ex officio the decision to cancel the fiscal obligations targeted by the law. The application procedure will be established by order of the ANAF president within 30 days from the date the law comes into force.
- Submit a reimbursement request to the competent fiscal authority if you have already paid the fiscal debts canceled by this law. The statute of limitations for submitting the request begins to run from August 24, 2026.
- Analyze the company’s fiscal situation to confirm if you fall within the provisions of the law, especially if you have received tax assessment decisions for VAT differences after the cancellation of the VAT code or, in the case of agricultural cooperatives, for VAT deduction on machinery.
Source: Official Gazette, Part I, no. 700 of August 24, 2026.
Note: This material is strictly for informational purposes and does not constitute legal, fiscal, or business advice. As the interpretation and application of legal provisions may vary significantly depending on the specific circumstances of each entity, we recommend seeking specialized legal assistance before adopting any operational decisions based on these changes.