Suspension of an ANAF Tax Assessment Decision Worth Approximately RON 3.3 Million Upheld on Appeal

The Cărămidariu Druță Bunu SCA team obtained a favorable solution in administrative and tax litigation concerning the suspension of enforcement of an ANAF tax assessment decision and related fiscal administrative acts totaling approximately RON 3.3 million, equivalent to roughly EUR 650,000, representing additional VAT assessed for the years 2019-2025.

The case concerns a company active on the Romanian food supplements market, one of the significant players in this sector and the Romanian representative of well-established producers from the United States and Europe.

On March 16, 2026, the Alba Iulia Court of Appeal dismissed as unfounded the appeal filed by the tax authority against the judgment delivered by the Sibiu Tribunal on January 30, 2026, by which the suspension request submitted by our team had been granted.

The first-instance court held that the statutory conditions for suspension were met, namely the existence of a clear appearance of unlawfulness affecting the contested act, as well as the need to prevent imminent damage. The confirmation of that solution on appeal provisionally validates the strength of the arguments advanced in the client's defense.

These two court rulings represent a significant procedural success, as they suspend the effects of the challenged fiscal acts and remove, at least temporarily, the risk of enforcement of substantial tax liabilities until the final resolution of the proceedings seeking their annulment.

The client was assisted and represented by Dan-Adrian Cărămidariu, PhD, attorney-at-law and Alexandra Bob, PhD, attorney-at-law, members of the tax law and administrative litigation practice of Cărămidariu Druță Bunu SCA.