Prescripția dreptului de a stabili creanțe fiscale
The prescription of the right to establish tax receivables

Summary/Abstract: Beginning 2020, the High Court of Cassation and Justice had ruled again confirming the private sector’s vision on the moment from which the 5 year tax statute of limitations starts, namely – the 1st of January of the year following that when the taxable base was generated; therefore 1st of January 2010 for the year 2009, etc. The tax authorities’ position was, as always, that the statute of limitations starts from the 1st of January of the year following that when the taxpayer declares the taxable base, which basically meant adding another year to the 5 year statute of limitations.

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