Preliminary assessment of the third payment request of Romania (2024)

                  Related Measure: Improving tax and tax administration processes, including
Number: 222
                  through the implementation of integrated risk management
Name of the Target: Share of the number of desk audits reported on the total audits carried out by
the tax administration - 30%
Quantitative Indicator: percentage (%)  Baseline: 0             Target: 30     Time: Q4 2022
Context:

Target #222 is part of investment C8.I2, which seeks to enhance tax compliance, foster a competitive market environment by reducing tax avoidance and evasion, and contribute to meeting the planned budget revenue through improved efficiency in tax collection.

Target #222 requires that 30% of the total audits carried out by the National Agency for Fiscal Administration (ANAF) are documentary audits (desk audits).

Target #222 is the second step of the implementation of investment C8.I2, and it follows the completion of target #220, which requires at least 150 000 cash registers connected to ANAF’s servers. It is accompanied by target #221 in this payment request, which requires that at least 600 000 cash registers are connected to ANAF’s servers. Target #222 will be followed by targets #219, #223, #224, #225, #226 and #226a, related to: staff training on the risk management system; a 60% share of the number of desk audits reported on the total audits carried out by ANAF; increase the number of audits by 10%; fully operational electronic risk register; Big Data/Analytics platform set- up and operational; and operationalisation of tax administration systems.

The investment has a final expected date for implementation on 31 December 2025.

Evidence Provided:

The following evidence was provided:

i. Summary document duly justifying how the milestone (including all the constitutive elements) was satisfactorily fulfilled; ii. Copy of the Order of the President of ANAF No. 3632/2020 regarding the establishment of certain documentary verification competencies, published in the Official Journal No. 921 of 9 October 2020; iii. Copy of the Order of the President of ANAF No. 3666/2020 and its annexes regarding the approval of the model and content of the forms and documents used in the documentary verification activity, published in the Official Journal No. 938 of 13 October 2020; iv. Report No. A.DCA289/ 9 March 2023 by the internal audit services within ANAF (hereinafter referred to as “the ANAF internal audit report”); v. Copy of Law No. 207/2015 on the Fiscal Procedural Code. Analysis:

The justification and substantiating evidence provided by the Romanian authorities covers all constitutive elements of the target. Specifically:

The share of the documentary audits in total audits carried out shall increase to 30% by Q4 2022 (from today’s zero). This target is part of the reform to shift inspection actions from physical to digital control structures.

On page 19 the ANAF internal audit report states that a total of 46 898 audits were conducted in 2022, out of which 19 061 were documentary audits, constituting 40.64% of all audits. The audit