On 14.05.2026, the Ministry of Finance approved Instruction No. 10, implementing Law No. 84/2025 “On the Fiscal Peace Agreement”, establishing the specific procedures for the application and conclusion of the agreement between taxpayers and the tax administration for the year 2026.
Who may apply?
A taxpayer who has submitted the annual Corporate Income Tax (CIT) return or the Personal Income Tax from Business (PITB) return, and who, during the previous tax year, generated gross income exceeding ALL 14 million.
Application by the taxpayer:
must be submitted by 31 March of the year for which the agreement is requested;
is submitted through the e-Filing system, within 31 March of the year for which the agreement applies.
Following the taxpayer’s application, the system automatically creates the respective case in the e-Filing system.
The application is automatically rejected in cases where the taxpayer has unpaid or undeclared tax liabilities.
Drafting of the Agreement
The system automatically generates the “Fiscal Peace Agreement”, which includes:
– the estimated taxable profit (increased by 18% compared to the previous year), the applicable tax rate for the estimated taxable profit and any additional profit, as well as the calculation and allocation of advance instalments throughout the year;
– if requested by the taxpayer, the right to restate the financial statements in accordance with the conditions provided by law.
The draft agreement is electronically signed and sealed by the head of the Regional Tax Directorate (DRT), and the document is sent to the taxpayer by 10 April of the year for which the agreement is concluded (the current year).
Attention! The agreement terminates when:
– the economic activity changes;
– the required profit increase of more than 18% is not achieved;
– the business is suspended or closed;
– in cases of repeated tax violations, non-payment of obligations under the agreement, or failure to fulfil the conditions for restating the financial statements;
– profit increases by more than 50% compared to the previous year;
– the taxpayer itself applies for termination of the agreement.
