Solicitările de informații din partea autorităților și obligația de furnizare
Requests for information from authorities and the obligation to provide it

Summary/Abstract: In the context of the recent requests for information regarding related-party transactions, issued by the National Agency for Fiscal Administration (ANAF) to taxpayers pursuant to Articles 58 and 64 of the Tax Procedure Code, discussions have arisen concerning the legal basis and appropriateness of these measures. Although these requests do not appear to be aimed at determining an immediate individual tax situation, they may foreshadow the initiation of subsequent audits, either targeted at the respective taxpayers or within the framework of thematic inspections. Furthermore, some of the requested information is not explicitly stipulated as an accounting or tax/declarative obligation, which results in a significant additional burden for taxpayers, without a clear and transparent justification. The matter is particularly sensitive for large and medium-sized taxpayers, who already prepare transfer pricing documentation, submit the SAF-T declaration, and provide the authorities with detailed data. Under these circumstances, additional requests—issued with short deadlines and during the holiday season—naturally raise legitimate questions regarding the proportionality, appropriateness, and administrative fairness of the measures undertaken.

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