Verification of personal tax position, wealth deemed unexplained, reclassification of sole traders, occasional transactions treated as a business — assistance and defence for individuals facing tax-authority audits, available internationally.
In recent years, the tax authority has made the verification of individuals a priority. It is no longer only large fortunes that are targeted: risk analysis automatically compares declared income with income estimated from purchases, transactions and assets, and significant differences trigger checks that can end with considerable amounts to pay.
The typical procedure begins with a compliance notice — an invitation to align voluntarily. If the differences remain unexplained, there follows the notice of verification of the personal tax position, then the verification itself and, finally, a tax assessment. Each stage has its own deadlines and every answer given counts.
What is at stake is not only tax. A large difference between declared and estimated income can be regarded, beyond the additional tax, as an indication of tax evasion or, in the case of complex flows, of money laundering. This is why the way you respond from the very first phase can make the difference between a clarification and a criminal file.
Beware of the 70% rate. For income whose source is not identified, the legislation adopted in 2023 increased the tax rate. In concrete terms, wealth you cannot document can be taxed at a far higher level than ordinary income — which is why a documented, prepared defence is essential.
If you find yourself in one of the situations below, an early assessment of your position makes the difference.
The authority has informed you that, following a risk analysis, it has identified discrepancies between estimated and declared income. It is not a mere letter — it is the step that precedes verification.
Property, vehicles, financial assets whose value exceeds your official income. The authority compares assets with income and requires the difference to be justified.
The authority considers that your sole-trader relationship with a client is, in fact, employment-like, and recalculates tax and contributions as for an employee.
Repeated online sales, real-estate or goods transactions, which the authority reclassifies as a continuous economic activity, and therefore taxable.
Amounts from work, investments or other foreign sources, which the authority claims should have been declared in Romania. The foreign-income notification programme has been active for years.
Gains from crypto-assets, stock-market transactions or other investments that the authority considers undeclared or incorrectly declared.
Whatever the situation, the first useful step is not to give the authority hasty explanations, but to understand, with a specialist, what you are accused of and how a documented justification is built.
The authority signals the discrepancies and invites you to comply voluntarily. It is the ideal moment to act — a documented explanation now can close the matter before it escalates.
If the risk remains, the authority issues the notice of verification of the personal tax position. A formal procedure begins, with its own rights and deadlines for the taxpayer.
The verification ends with a decision establishing, where applicable, additional obligations. This can be challenged — administratively, then in court — on technical substance.
Building a documented justification of the sources of income and wealth, from the amicable phase, before the differences are recorded in a decision.
Representation and strategy during the verification of the personal tax position: which documents, what explanations, how your position is protected.
Attacking the decision on its substance — the calculation method, the estimate of wealth, the sources deemed unexplained — administratively and, if needed, in court.
When the verification touches the area of evasion or money laundering, coordinating the tax defence with the criminal one, by the same person.
Yes, and the way you respond is essential. The compliance notice is an invitation to clarify the discrepancies voluntarily, before the formal verification begins. A well-documented response at this stage can close the matter without consequences.
Important: do not ignore the notice and do not respond hastily, without understanding exactly what you are accused of. Both can disadvantage you. A prior assessment of the situation establishes what to communicate and how.
The authority estimates your income on the basis of your assets — property, vehicles, financial assets, transactions — and compares them with what you declared. If there is a significant difference you cannot document, that difference can be treated as unexplained income and taxed, under the law, at an increased rate.
The key to the defence is documented justification: loans, inheritances, prior savings, sales of personal goods, sums received — all can lawfully explain an increase in wealth, if properly proven.
It is the reclassification of independent activity as dependent activity. If the authority considers that your relationship with a client has the characteristics of an employment relationship — subordination, a schedule, a single beneficiary, resources provided by it — it can recalculate the obligations as for an employee, with higher tax and contributions.
The defence is built on the legal criteria of independent activity and on the concrete reality of the collaboration. It is not the legal form that decides, but how the activity looks in fact — and this can be demonstrated.
It depends on the nature of the transactions. The occasional sale of goods from personal assets is not, in principle, taxable economic activity. But if the sales are continuous, made for profit and involve a degree of organisation, the authority can reclassify them as independent activity, and therefore taxable.
The line between an occasional sale and an economic activity is one of fact, assessed case by case. If you have already received a request to this effect, an assessment of the situation clarifies where you stand.
Yes, it is a real risk when the differences are large or when elements of concealment of sources appear. A tax verification can give rise to suspicions of tax evasion or, in the case of complex flows, money laundering.
This is precisely why coordinating the tax defence with the criminal one, from the first phase, is important — and the fact that the same person covers both sides avoids any misalignment between a tax strategy and a criminal one.
Yes, assistance for individuals is available internationally. Documents can be sent electronically, and consultations take place by phone, by video conference or in writing. For a tax-authority audit, what matters is a prompt response, not the location.
Deadlines run from the moment of communication. A first conversation clarifies what you are accused of, what you must justify and how the defence is built — before an estimate becomes a tax assessment.