A new regime for tax fines is taking effect, as the Ministry of National Economy and Finance is implementing significant changes to the Code of Tax Procedures, drastically limiting the instances in which fines are imposed for late tax returns.
The regulation affects thousands of taxpayers and businesses that either filed returns late or failed to file them, without, however, any actual tax liability arising.
The changes take effect immediately following the publication of Law 5301 on May 15, 2026, and provide for retroactive refunds dating back to 2024 for those who have already paid fines.
When fines are “waived”
Under the new framework, fines will no longer be imposed in the following key cases:
- Late income tax returns with a zero or credit balance.
- Returns where the tax due does not exceed 100 euros.
- Late returns of an informational nature with no tax liability.
- Returns for indirect taxes, fees, or contributions—excluding VAT and FMA—when the tax does not exceed 100 euros.
- Withholding tax returns with an amount up to 100 euros.
At the same time, fines are being abolished for returns involving minors or tax obligations from years during which the taxpayer was a minor.
What’s changing with VAT
For late VAT returns, the fine is not completely abolished, but it is significantly reduced.
Specifically, when no tax is due, the fine is reduced to 100 euros, instead of the 250 or 500 euros that applied until now, depending on the category of business or professional.
At the same time, the €100 fine for special VAT regimes is also being abolished.
Exemptions for amended returns
The new regulation also covers amended returns filed to correct errors.
No fine will be imposed:
- when an amended income tax return results in additional tax of up to 100 euros,
- as well as in amended VAT or withholding tax returns, provided that the original return was filed on time.
Retroactive refunds for two years
The new provisions apply retroactively from April 19, 2024.
This means that taxpayers who have already paid fines that are now being waived or reduced will be entitled to a refund or offset against other debts.
According to reports, the Independent Authority for Public Revenue (AADE) is expected to issue detailed guidelines on the refund and offset process in the near future.
In cases where fines have not yet been collected, the assessment process will automatically cease.
Source: APE-MPE