An audit notice from Romania’s tax authority, ANAF, instantly raises tension in any company, regardless of size. Yet a tax audit is not a nightmare when the accounting is kept correctly, the supporting documents are complete and the returns match the economic reality. The difference between a calm audit and a stressful one almost always comes down to preparation — not luck.
For foreign-owned companies, an extra layer applies: the outcome of a Romanian audit often affects reporting to the parent company and the application of double taxation treaties. That makes it even more important for the Romanian subsidiary to be audit-ready at all times.
In recent years, digitalisation has radically changed how inspectors work. Through e-Factura (electronic invoicing), SAF-T (the D406 return), e-Transport and the pre-filled VAT return (e-TVA), ANAF now has access to a vast volume of data that it can cross-check automatically before it ever sets foot in your business. In practice, a large part of the audit is done “from the desk”, and the inspector arrives with hypotheses already formed. This makes it critical that your internal data is consistent with what has been reported.
The types of audit ANAF can carry out
Before preparing, it helps to know what kind of action you are facing, because the scope and your rights differ:
| Type of action | What it involves | Indicative duration |
|---|---|---|
| General tax inspection | Reviews all tax obligations over a period (usually within the statute of limitations) | Weeks to months |
| Partial tax inspection | Targets a single tax or a single period (frequently VAT) | Shorter, focused |
| Unannounced control | Verification without prior notice on specific facts | Short |
| Documentary verification | “Desk” analysis based on data held by ANAF | No on-site presence |
| Anti-fraud control | Carried out by the DGAF, often unannounced, on fraud suspicions | Short, intensive |
In a classic tax inspection you usually receive an inspection notice (aviz de inspecție) indicating the period and obligations under review. This is the moment serious preparation begins — not the day the inspector arrives.
What inspectors check, in essence
Although every audit has its particularities, the inspectors’ attention almost always focuses on the same areas:
- VAT accuracy — output vs. input VAT, correct chargeability, treatment of intra-Community operations and reverse charge, consistency with the returns filed and with the pre-filled e-TVA.
- Deductibility of expenses — whether each expense has supporting documents, a genuine economic purpose and a link to the company’s activity.
- Revenue recording — whether all income is recorded and invoiced, with no “missing” or understated revenue.
- Reporting obligations — whether the returns (D300, D390, D394, D406/SAF-T, payroll returns) were filed on time and correctly.
- Consistency across sources — e-Factura, SAF-T, e-Transport, bank statements, trial balances and returns must “tell the same story”.
In other words, the inspector is looking for discrepancies: between what you declared and what the documents show, between what you reported and what your partners reported. Your role in preparation is to eliminate these discrepancies in advance or, where legitimate explanations exist, to be able to document them immediately.
The documents that must be up to date
A prepared company has, at any moment, a complete virtual “audit file”. Here is what you should be able to put on the table quickly:
- Issued and received invoices — complete, in chronological order, with all mandatory elements, reconciled with e-Factura.
- Bank statements for all accounts, plus the cash register where cash is used.
- Accounting registers — Journal, Inventory register, General ledger.
- Trial balances and filed annual financial statements.
- Tax returns filed and the related receipts.
- Contracts — with clients, suppliers, leases, loans, services (essential to prove the reality of operations).
- Personnel files — employment contracts, addenda, payslips, timesheets, proof of REVISAL/REGES submission.
- Transport documents — delivery notes, CMR, UIT codes from e-Transport, where applicable.
- Supporting documents for special expenses — logbooks for vehicles, entertainment documents, travel expense reports.
The golden rule: every accounting entry must be backed by a supporting document, and every document must reflect a real operation. An accountant who keeps orderly records saves you entire days when the audit comes. This is where the support of a specialised firm makes the difference — see our accounting and tax advisory services to understand how we keep your records permanently audit-ready.
The sensitive points that trigger most discussions
In our experience, most adjustments proposed by inspectors concentrate on a few recurring categories. Handle them correctly from the outset and you dramatically reduce the risk.
Expenses at the limit of deductibility
Entertainment (protocol) expenses, vehicle costs (where a limitation on VAT and expense deduction frequently applies, usually 50% for vehicles not used exclusively for business), vouchers, gifts and social expenses are classic checkpoints. Make sure you observe the applicable ceilings and hold the documents justifying business use. Note: percentages and ceilings may change; verify the value in force for the tax year under review.
Transactions with related parties
Transactions between companies in the same group draw special attention to transfer pricing. If your company carries out significant operations with affiliates — including the foreign parent company — you must be able to demonstrate, through the transfer pricing file, that prices respect the arm’s length principle where the thresholds require it. This point is particularly relevant for foreign-owned companies reporting to a group abroad.
VAT differences versus the pre-filled return
With e-TVA, ANAF provides a VAT return pre-filled from e-Factura and other sources. Any significant difference between what you declare and what appears pre-filled may trigger a compliance notice and, later, an audit. Check these differences monthly and keep the explanations documented.
VAT deductions from “problematic” suppliers
If a supplier is declared inactive, has a cancelled VAT number or is suspected of fraud, your right to deduct may be challenged. Periodically checking partners in ANAF’s registers is a simple preventive measure.
How to prepare your company in advance — practical steps
Preparation does not begin when the notice arrives; it is part of the monthly routine of a healthy company:
- Monthly reconciliation between e-Factura, VAT journals, bank statements and the trial balance.
- Checking the pre-filled e-TVA return and documenting any differences.
- Orderly archiving of documents, digital and physical, easy to retrieve by period and type.
- Periodic review of sensitive expenses (entertainment, vehicles, travel).
- Checking the tax status of key partners.
- An annual “internal audit” that simulates a control and identifies risks before ANAF does.
During the audit itself, a few rules of conduct matter enormously: provide only the documents requested, answer to the point, do not improvise explanations, and involve your accountant or tax advisor from the first contact. You have the right to be assisted by a specialist, and at the end of the inspection you have the right to express your point of view before the assessment decision is issued — a moment when well-documented arguments can completely change the outcome.
What to do if you disagree with the outcome
If, following the audit, you receive an assessment decision with additional amounts you consider unjustified, you have the administrative appeal (contestație), which must be filed within a legal deadline from the communication of the decision. If it is rejected, you can turn to the administrative court. That is why it is essential that, already during the audit, all your observations and documents are recorded correctly — they become the basis of any future appeal. Discover in the how we help section how we support you not only in preparing documentation, but also in representation before the tax authorities.
Conclusion
An ANAF audit ultimately tests your company’s long-term fiscal discipline. If you keep your records up to date, reconcile the data monthly with ANAF’s sources and handle the sensitive points correctly, the audit becomes an administrative formality rather than a crisis. The key is continuous preparation, not a last-minute reaction.
At Conta Fiscal — CECCAR members with over 20 years of experience — we prepare the documentation, verify the critical reconciliations and assist you throughout the audit, from the inspection notice to any appeal. Contact us for an assessment of your company’s audit readiness before ANAF knocks at the door.
Frequently asked questions
How far in advance does ANAF announce an audit?
For a tax inspection, you receive an inspection notice stating the period and obligations under review. However, there are also unannounced or anti-fraud controls that may take place without prior notice.
Which documents does an ANAF inspector request most often?
Issued and received invoices, bank statements, accounting registers, trial balances, filed tax returns, contracts and personnel files. All must be consistent with the data in e-Factura and SAF-T.
Is this topic particularly relevant for foreign-owned companies?
Yes. Audit outcomes often affect reporting to the parent company and double taxation treaties. Transfer pricing on transactions with related parties is an especially sensitive area for foreign-owned groups.
Can I be assisted by an accountant or tax advisor during the audit?
Yes. You have the right to be assisted by a specialist throughout the inspection. We recommend involving your accountant or tax advisor as soon as you receive the inspection notice.
What do I do if I disagree with the assessment decision?
You can file an administrative appeal within the legal deadline from the communication of the decision; if it is rejected, you can turn to the court. Correct documentation during the audit is essential for the appeal’s success.