The Fiscal Procedure Code has been recently modified, through Government Ordinance no. 5/2020, published in the Official Journal no. 68/2020.
As previously mentioned, the pronouncement transposes the provisions of the Council Directive 2018/822/EU amending Directive 2011/16/EU regarding the mandatory automatic exchange of information in the field of taxation concerning the cross-border arrangements that are subject to reporting.
According to the explanatory note, the ordinance requires intermediaries to report any information to tax authorities, regarding certain cross-border arrangements that could be used to gain tax advantages (transferring profits to more beneficial tax regimes, reducing the taxes due etc.).
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