Cauze de neaplicare a amnistiei fiscale. Aspecte practice privind incidența prescripției și imputația plății în dreptul fiscal
Causes of non-application of the tax amnesty. Practical aspects regarding the incidence of prescription and imputation of payment in tax law

Summary/Abstract: By adopting the Government Ordinance no. 6/2019 on the adoption of fiscal facilities, the Government Emergency Ordinance no. 69/2020 amending and supplementing the Law no. 227/2015 on the Fiscal Code and adopting fiscal measures and the Government Emergency Ordinance no. 19/2021 regarding fiscal measures, amending and supplementing fiscal normative acts, a series of “tax amnesties” have been enacted to help taxpayers with outstanding debts. Although meant to help them, when using this procedure taxpayers encountered problems that again raise the discussion on the statute of limitation and the receivables on which the payment is imputed on.

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