Sinteză de jurisprudență fiscală națională
Synthesis of national tax case law

Summary/Abstract: The article reviews a recent Romanian court decision concerning the reduction of non‑declaration penalties when tax liabilities are paid or scheduled for instalment. The court held that the two legal scenarios for reducing penalties must be interpreted independently and that partial payments made before an instalment plan should not lead to different treatment of identical tax liabilities. When fiscal provisions allow multiple interpretations, the principle in dubio contra fiscum requires that ambiguity be resolved in favour of the taxpayer. The case illustrates how courts apply interpretative safeguards to ensure proportionality and fairness in tax enforcement.

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