Fiscal Amnesty Measures Adopted for 2025
On December 2, 2024, the Assembly of the People's Representatives (ARP) adopted fiscal amnesty measures for 2025, aiming to simplify the regularization of tax debts and exempt taxpayers from fines and financial penalties. These measures concern several types of tax debts and recovery procedures, under certain conditions.
Eligible Taxpayers Taxpayers can benefit from the cancellation of:
- Control fines
- Late payment fines
- Recovery fees related to state tax debts
provided they pay the outstanding amounts in one lump sum or subscribe to a payment schedule, with the first installment settled before June 30, 2025. This measure applies to:
- Tax debts recorded in the accounts of tax collectors before January 1, 2025
- Tax debts recorded after this date, related to a tax audit with notified results and a settlement concluded before June 20, 2025, or those inscribed in forced recovery decisions notified before this date
- Tax debts subject to judicial decisions concerning tax disputes, recorded before June 20, 2025
50% Exemption on Administrative Fines A 50% exemption on fines related to administrative tax offenses is also provided, subject to the same payment conditions.
Payment Schedule The payment schedule for these tax debts can extend up to five years, depending on the debtor's category and the remaining amount to be recovered. A motivated request can allow for an extension of this schedule, with a maximum period of five years.
Suspension of Recovery Procedures Recovery procedures are suspended if payments are made within the deadlines. In case of non-payment of an installment, legal measures are immediately reactivated, with a late payment fine of 1.25% per month or part of a month of delay. The right to exemption is cancelled if a payment is not made within 120 days after the deadline of the last payment.
Cancellation of Fines Fines due under Articles 81, 82, and 85 of the Tax Code are cancelled for tax declarations (including contracts and writings) with a deadline prior to October 31, 2024, and which have not been prescribed, provided that the declarations are filed between January 1, 2025, and June 20, 2025, and the principal amount of the tax is paid at the time of filing.
Exemption from Court-Ordered Fines Amounts due in respect of fines and financial penalties pronounced by courts before January 1, 2025, as well as related recovery fees, are cancelled. However, this exemption does not apply to fines related to bounced checks or offenses related to combating terrorism and money laundering.
