2026 Update
Receiving a notification of additional tax assessment from the Tax and Customs Authority (AT) can be cause for concern, but it is essential to remain calm and follow well-defined procedures. This article explains the steps that the company should take — from analysing the notice to any eventual appeal or tax adjustment — in accordance with the tax regime updated by the 2026 State Budget.
1. Understanding Additional Tax Assessments
An additional tax assessment occurs when the AT believes that the company has not correctly declared or paid the tax due, based on inspections, automatic data cross-checks or document checks.
It may apply to:
• VAT: undue deductions, billing omissions, calculation errors or undeclared exempt transactions;
• IRC: corrections to taxable income, misapplied tax benefits, costs not accepted for tax purposes or insufficient documentary evidence.
The notification must indicate:
• Reasons for the assessment and applicable legal provisions;
• Additional amount calculated and compensatory interest (currently at an annual rate of 5.7%);
• 30-day deadline for voluntary payment;
• Right to complain or appeal, in accordance with the Tax Procedure and Process Code (CPPT).
2. Detailed Analysis of the Situation
As soon as the notification arrives, managers should:
a) Assemble the technical team
The company’s certified accountant and/or tax consultant should be immediately involved to analyze:
- What is the tax period in question?
- What are the grounds presented by the IRS?
- Are there obvious errors, questionable interpretations, or even illegalities?
b) Compare with internal accounting
Many settlements result from formal errors or oversights, such as:
- Incorrectly recorded invoices;
- Costs entered without supporting documentation;
- Duplication of amounts;
- Lack of communication of elements in the e-Invoice or SAF-T.
Technical analysis can enable you to voluntarily correct minor errors or prepare a solid defence if the settlement is improper.
3. Assess the Possibility of Payment or Dispute
The company must decide whether to settle or contest the assessment.
a) Voluntary payment
If the assessment is accepted, payment within 30 days avoids:
• Additional interest on arrears;
• Enforcement costs;
• Seizures or fines.
It is possible to request payment in instalments for up to 36 months, provided that the request is submitted within the legal deadline and that the amount owed does not exceed the limits defined in Article 196 of the CPPT.
b) Administrative appeal
If there are grounds for illegality, the company may file an administrative appeal within 120 days of notification.
The appeal does not automatically suspend tax enforcement, unless a bank guarantee or surety bond is provided.
c) Judicial challenge
If the administrative decision is not favourable, a judicial challenge may be filed with the Tax Court within 90 days.
This remedy is appropriate when the amount is high or there is favourable case law (e.g. decisions of the CAAD or the Central Administrative Courts).
4. Regularize and Prevent Future Situations
After settling the accounts, it is essential to strengthen internal control:
a) Internal tax audit
Review accounting procedures, VAT deduction, expense classification and application of tax benefits (such as SIFIDE II or RFAI).
b) Team training
Ensure constant updating in line with the new IRC and VAT rules introduced by the 2026 State Budget, including the mandatory electronic invoicing regime and the new framework for deductible expenses.
c) Periodic external consulting
Larger companies or those in high-risk sectors (retail, construction, catering) should consider annual tax audits conducted by independent consultants.
5. Communication and Recording
The company must communicate the settlement internally to management and:
• Record the debt and associated charges in the accounts;
• Reflect the impact on the income statement and cash flow statements;
• Ensure proper reporting in the IES and financial statements.
Final Notes
An additional tax settlement should not be viewed as a catastrophe, but rather as an opportunity to strengthen fiscal rigour and internal governance.
Acting quickly, with qualified technical support, is essential to protect the company’s cash flow and reputation.
The 2026 State Budget reinforces the role of tax compliance, promoting phased payment mechanisms, digitisation and transparency.
The best defence remains prevention, through good accounting practices, continuous training and ongoing professional monitoring.