Dear Madame / Dear Sir,

According to a recently published release, ANAF has announced that following a risk analysis performed by the General Department of Coordination of the Tax Audit within ANAF on the large taxpayers mamaged, starting from 01.01.2017 a number of around 108 large taxpayers with a high fiscal risk was selected for which tax audit actions will be started.

We draw attention to the fact that the main criterion used in this risk analysis was the fiscal risk related to transfer prices, and mong the other criteria are also the profit margin, inconsistencies between D394 and D390, transactions with taxpayers declared inactive/ deleted TIN (tax identification number).

We mention the fact that, for a number of around 80 of the selected taxpayers, the tax audits will be performed by the general regional directorates by delegation and the remaining 28 taxpayers were included in the program of the tax audit structures of the General Directorate of Large Taxpayers Administration.

We note that these approaches to start the tax audits are performed in accordance with point 11 of the Main courses of action of ANAF in 2017, meant to increase the level of collecting budgetary revenue, by which was established the selection and programing in tax audit starting from the immediately following period of a larger number of large taxpayers with a special focus on companies in the financial-banking field and medium taxpayers, including by granting delegations to other structures.”

In the context of the previously mentioned, the Darian DRS Tax is at your disposal in case you identify potential risks at the level of your company to discuss them and we are expressing our availability to assist you in the course of possible tax audits.

Sincerely,
The Darian DRS Tax team