- within Media, Telecoms, IT, Entertainment and Law Practice Management topic(s)
On September 26, 2025 the Head of the Revenue Service issued Order No 20688 introducing a new instruction for the cancellation of 50% of fines imposed as a result of tax audits, including those arising from interim tax audit acts.
Eligibility Criteria
Fifty percent (50%) of the accrued fines may be canceled if the taxpayer fully pays the taxes listed in the tax demand, along with 50% of the fines, to the state budget within 30 days from the issuance of the tax demand resulting from the audit. This indicates that the taxpayer has acknowledged the amount specified in the relevant tax demand within the same period.
There are a few steps to follow to be eligible to this benefit.
- The accrued amounts must be paid in full regardless of whether the taxpayer has an excess balance or an outstanding debt on his personal tax card. The taxpayer is required to transfer to the treasury 100% of the accrued tax and 50% of the accrued penalty calculated on the tax demand to the appropriate budget account.
- The taxpayer must acknowledge the amounts assessed in the tax claim within 30 days of its issuance. To do this, the taxpayer must submit an application to the tax authority on the refusal to appeal the tax claim.
- Final step: Within 30 days from the issuance of the tax demand the taxpayer must submit a written application to the tax authority “Request of the cancellation of 50 percent of the amounts of fines accrued as a result of the tax audit”, which shall be submitted together with the above-mentioned application “On refusal to appeal the tax claim”. The application shall be accompanied by document(s) confirming the payment of the relevant amounts to the budget.
Application Review Procedure
The tax auditor shall review the application within 10 working days. If any deficiencies are identified, the payer will be granted another 10 calendar days to correct them. If there are no deficiencies, the auditor shall issue a conclusion of the cancellation of 50% of the fines or in negative case a refusal to cancel fines.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
