Taxpayers may submit a motivated written application to the SRS requesting that the SRS adopt a decision on voluntary payment of delayed taxes by setting a deadline for the taxpayer for a term of up to three years if a decision on the recovery of the delayed taxes has already been adopted concerning the taxpayer and such a decision was not adopted more than six months ago, and there are no pending insolvency-, legal protection-, or extrajudicial litigation proceedings. The application may be submitted through the SRS’s Electronic Declaration System, via mail, or in person.

The use of Legal Protection Proceedings

If the taxpayer is confident that he or she will be able to solve financial difficulties by implementing legal protection proceedings, the taxpayer should keep in mind that, in the cases provided by the Insolvency Law, the consent of the SRS is required for the implementation of the plan of measures of legal protection proceedings. An application asking the SRS’s permission for the execution of the plan of measures of legal protection procedures, together with the plan of measures of legal protection proceedings attached thereto, may be submitted electronically, by post, or in person.

Filing an insolvency petition

If there are reasons to believe that the obligations of late tax payments cannot be met, the taxpayer should apply to the court for bankruptcy procedures.

The delayed and suspended tax recovery process 

The recovery of late tax payments is carried out in compliance with Section 26 of the Law on Taxes and Duties, based on the decision to collect late tax payments and using the following recovery measures:

Bank account of a taxpayer

Based on a collection order on behalf of the SRS, cash should be written off from the taxpayer’s bank account with the bank or from an account created with any other legal person who is not a credit institution and is involved in the business of non-cash settlements.

Office of the Cashier

Cash may be confiscated from a legal person’s or individual merchant’s cashier’s office or other locations of storage in compliance with the Cabinet of Ministers’ regulations.

Taxpayer’s property

The recovery of delayed tax payments on an uncontested basis must be applied to the taxpayer’s property (moveable and immovable property, including property placed with third parties) following the procedures outlined in Part E of the Civil Procedure Law. The recovery of the property must begin if the tax administration has been unable to satisfy the delayed tax payments and the expenses concomitant to their recovery on an uncontested basis from tax overpayments, collection orders, and cash seizures. The tax administration or a sworn bailiff implements the judgment on the collection of late tax payments.

Recovery of delayed tax payments on an uncontested basis

If at least one of the following requirements is met, the recovery of delayed tax payments on an uncontested basis will not begin and the recovery that has already begun will be postponed.


The decision made based on the results of the control procedure conducted by the tax administration has been contested


The due term for the payment of the tax has been extended, deferred, or divided into installments


The taxpayer is required to make all current tax payments following the rules established by tax laws after the declaration of insolvency or the beginning of legal protection proceedings in court


The tax administration has adopted a decision on voluntary payment of delayed taxes.

Restraints on the violation

The following measures limiting violations may be applied to the taxpayer if they do not exercise their rights under the Insolvency Law to file a petition for insolvency with the court or to pursue legal protection proceedings, nor do they voluntarily pay their tax debt by using any of the options made available by the tax laws:

  • a natural person may be added to the list of individuals at risk
  • The SRS may interrupt the taxpayer’s or structural unit’s economic activities
  • A Management Board member or natural person can be fined 280 to 700 euros, with or without losing office
  • Failure to pay taxes or tax-equivalents can result in criminal charges