Effective 1 September 2026, the Director of the State Tax Inspectorate (VMI) issued Order No. V-57, amending the 2007 Order No. VA-66 on the Rules for Consultation and Information Provision at the State Tax Inspectorate. The amendment modernizes the framework for taxpayer assistance, aligning it with the Law on Tax Administration (MAĮ) Article 12 and the OECD Guidance on Cooperative Compliance. Key changes include the introduction of a formal “Advance Pricing Agreement (APA) Pre-Filing Consultation” procedure, mandatory response timelines for written inquiries (15 business days for standard requests, 30 for complex transfer pricing issues), and the establishment of a dedicated Large Taxpayer Unit (LTU) helpdesk for groups with annual turnover exceeding €50 million. The order also codifies the confidentiality protections for information disclosed during consultations, referencing Article 58 of the MAĮ and GDPR Article 6(1)(c).
Key Takeaways
- Structured APA Pre-Filing Process: Multinational enterprises can now request a formal pre-filing meeting with the LTU to discuss APA scope, methodology, and comparability analyses before submitting a full application, reducing uncertainty and processing time by an estimated 40%.
- Binding Response Deadlines: VMI commits to written responses within statutory deadlines; failure to respond within the prescribed period allows the taxpayer to escalate to the Minister of Finance under Article 62 of the MAĮ, enhancing accountability.
- Digital Consultation Platform: All consultation requests must be submitted via the VMI self-service portal (e. VMI) using the new “Consultation Module,” enabling tracking, document exchange, and automated deadline monitoring.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement