PENALITATEA DE NEDECLARARE ÎN NOUL COD DE PROCEDURĂ FISCALĂ

The New Fiscal Procedure Code introduces a novelty, the penalty for non-declaring. This penalty is a specific sanction that amerces a certain behaviour of a taxpayer consisting in non-declaring or wrongfully declaring main tax obligations. The penalty has a significant practical impact in case of both administrative irregularity and criminal irregularity. The nature of this penalty, the legal conditions of occurrence and the procedure of infliction cause some interrogations including an eventual exam of constitutionality.