Impozitarea veniturilor din surse nedeclarate în lumina principiilor fundamentale aplicabile în materie fiscală
Taxation of Income from Undeclared Sources in Light of Fundamental Principles Applicable in Tax Matters

Summary/Abstract: This paper examines the compatibility of the legal framework governing the taxation of undeclared-source income, as regulated by Article 117 of the Tax Code, as amended by Law No. 296/2023, with the fundamental principles applicable in tax matters. Although the introduction of an increased 70% tax rate applicable to income obtained by individuals from undeclared sources was formally justified by the need to increase the collection of budgetary revenues and to discourage tax evasion, it raises a number of issues of principle, such as the degree of clarity and foreseeability of the tax rule, its compatibility with the principles of tax fairness and proportionality, as well as its impact on the exercise of the taxpayer’s right to property.

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