The Committee for the Out-of-Court Settlement of Tax Disputes has been granted a new extension, as a provision included in the omnibus bill of the Ministry of National Economy and Finance (Ministry of National Economy and Finance), its operations will continue, accepting applications at least until the end of December 2026.
Consequently, taxpayers who have been fined by the Tax Authority for tax violations may request to settle their disputes with the Tax Authority out of court, seeking a reduction in fines of up to 75%, until December 31, instead of July 24 of this year.
In fact, the time limit for cases eligible for the procedure is also being extended: requests for out-of-court settlement may now pertain to cases that are pending and have not been heard by December 30, 2026, instead of July 23, 2026.
In any case, the new extension provides yet another opportunity for those who wish to submit new applications electronically or have pending tax disputes before the Council of State or the regular administrative courts and wish to seek a resolution without waiting for the judicial process to run its full course
In fact, the provision does not apply only to pending cases. It allows for the filing of a new application for cases that were dismissed on procedural grounds. The same applies to cases that were dismissed or rejected, provided that new evidence has emerged, new case law has been established, or a final criminal court decision has been issued.
When will they be reviewed
An extension is also granted for the time limits within which the Commission must examine the applications. The deadline is extended to July 31, 2027, while out-of-court settlement agreements may be issued until October 31, 2027.
The term of office of the Director General, the members of the Commission’s Divisions, and the Secretaries also expires on that date. If an application is not examined by July 31, 2027, it is deemed to have been tacitly rejected.
The purpose of the extension is to resolve pending tax disputes more quickly, relieve the burden on the courts, and boost tax revenues. While the case is pending before the Commission, the court proceedings are suspended and the case is removed from the docket by order of the President of the court, without, however, affecting the possibility of interim judicial protection.
Grounds for the appeal
In his application, the taxpayer briefly sets forth the grounds which, in his opinion, support the appeal, through which he may request:
- Statute of limitations on the State’s right to impose the disputed tax or fine due to the expiration of the period within which the Tax Administration had the right to assess them.
- Statute of limitations on the State’s right to impose the disputed tax or fine due to the issuance of a tax certificate without reservation.
- Incorrect assessment of the tax or fine due to a manifest lack of tax liability or a numerical error.
- Retroactive application of the more favorable tax penalty in accordance with the established case law of the Council of State.
- Reduction of additional tax, interest, surcharges, and fines.
The Commission’s ruling
If the application is deemed admissible by the Committee, the taxpayer’s claims are examined based on case law and the established practice of the Tax Administration. In such cases, the application may be granted in part or in full.
If the sole claim is for a “reduction of the additional tax, interest, surcharges, and penalties,” the request is granted.
The Commission’s proposal is notified to the applicant, who may accept it within 10 business days of its notification; partial acceptance of the Commission’s proposal is not permitted.
Upon acceptance of the Commission’s decision, the pending dispute is irrevocably resolved, and the decision cannot be challenged by any legal remedy or means.
The taxpayer is required to pay 30% of the principal tax due, or 25% in the case of standalone fines, and to upload proof of payment to the relevant website.
Installments
The remaining amount is paid in 1 to 24 installments with discounts proportional to the number of installments selected, as follows:
- In a single installment with a 75% discount
- In 2–4 installments with a 65% discount
- In 5–8 installments with a 55% discount
- In 9–12 installments with a 50% discount
- In 13–16 installments with a 45% discount
- In 17–20 installments with a 40% discount
- In 21–24 installments with a 35% discount
If two consecutive monthly installments are not paid or if payment of the last two installments is delayed for the corresponding period, the settlement is retroactively revoked, deemed never to have taken place, and any amounts paid are considered to have been paid against the original debt.