Proposal for a COUNCIL IMPLEMENTING DECISION authorising Romania to introduce a special measure derogating from Articles 218 and 232 of Directive 2006/112/EC on the common system of value added tax
Date: 2023-06-23
Institutions: Directorate-General for Taxation and Customs Union, European Commission
Subjects: Romania, VAT, derogation from EU law, e-invoicing, establishment, tax collection, taxpayer

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   EUROPEAN COMMISSION  Brussels, 23.6.2023  COM(2023) 329 final 2023/0190 (NLE)  Proposal for a COUNCIL IMPLEMENTING DECISION authorising Romania to introduce a special measure derogating from Articles 218 and 232 of Directive 2006/112/EC on the common system of value added tax  
 
EXPLANATORY MEMORANDUM 

Pursuant to Article 395(1) of Directive 2006/112/EC of 28 November 2006 on the common 
system of value added tax1 (hereafter 'the VAT Directive'), the Council, acting unanimously 
on  a  proposal  from  the  Commission,  may  authorise  any  Member  State  to  apply  special 
measures  for  derogation  from  the  provisions  of  that  Directive  in  order  to  simplify  the 
procedure for collecting VAT or to prevent certain forms of tax evasion or avoidance. 

By  letter  registered  with  the  Commission  on  14  January  2022,  Romania  requested 
authorisation to derogate from Articles 178, 218 and 232 of the VAT Directive to be able to 
impose mandatory electronic invoicing for transactions between taxable persons.  

Further, by letter registered with the Commission on 30 September 2022, Romania modified 
its  request.  Accordingly,  Romania  confirmed  that  it  requests  the  authorisation  to  derogate 
only from Articles 218 and 232 of the VAT Directive and specified that the entry into force of 
the measure will be postponed to 1 January 2024, instead of 1 July 2022, which was the date 
originally requested. 

In accordance with Article 395(2) of the VAT Directive, the Commission informed the other 
Member States by letter dated 8 December 2022 of the request made by Romania. By letter 
dated  9  December  2022,  the  Commission  notified  Romania  that  it  had  all  the  information 
necessary to consider the request.  

1. 

• 

CONTEXT OF THE PROPOSAL 

Reasons for and objectives of the proposal 

Romania submitted a request for derogation, based on Article 395 of the VAT Directive, to be 
authorised  to  implement  an  obligation  to  issue  electronic  invoices  for  transactions  between 
taxable persons established in Romania. According to Romania, the main objectives pursued 
by the implementation of the mandatory electronic invoicing system are to combat tax fraud 
and evasion, to make collection more efficient, particularly in the area of VAT, to improve the 
competitiveness of economic operators and to reduce administrative costs for both taxpayers 
and the tax administration. 

The information in the invoices will be reported to the tax administration, who will therefore 
obtain this data in real time. This will allow the tax administration to carry out a timely and 
automatic verification of the consistency between the VAT declared and paid and the invoices 
issued  and  received.  This  possibility  will  help  Romania  to  increase  the  efficiency  and 
effectiveness of the fight against VAT fraud and evasion. 

In this regard, Romania has consistently recorded a high VAT gap in recent years. The latest 
report  published  by  the  European  Commission  shows  a  VAT  gap  of  35.7%  for  2020. 
According to Romania, this situation is indicative of a structural problem, which will require 
both urgent and sustained action, and the implementation of the necessary reforms. 

The introduction of mandatory e-invoicing and the reporting of the invoice data will achieve 
greater taxpayers’  compliance as  well as a deterrent  effect  in  terms  of  attempted fraud.  The 
envisaged system will entail, for instance, that participants in the ‘carousel fraud’ will become 
visible to the tax administration from the outset. Currently, participants in carousel fraud are 
difficult  to  identify  because  they  do  not  submit  VAT  returns  and/or  other  returns.  The 
introduction of generalised electronic invoicing will be a powerful tool for real-time tracking 

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OJ L 347, 11.12.2006, p. 1. 

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of the fraudulent chain, allowing tax authorities to take immediate action to identify and stop 
traders participating in this fraud. 

The introduction of mandatory electronic invoicing for transactions between taxable persons 
will also benefit economic operators through digitalisation and the reduction of administrative 
burden, while at the same time ensuring a fair competitive environment between companies. 
Some of the benefits of implementing electronic invoicing for economic operators are faster 
payments, saving on transmission costs, fast and cheap processing of invoice data and reduced 
archiving costs.  

Article 218 of the VAT Directive provides for an obligation for Member States to accept all 
documents  or  messages  both  in  paper  or  electronic  form  as  invoices.  Romania  would 
therefore like to obtain a derogation from the above-mentioned Article of the VAT Directive 
so that only documents in electronic form can be considered as invoices by the Romanian tax 
administration. 

Article 232 of the VAT Directive requires that the use of an electronic invoice shall be subject 
to  acceptance  by  the  recipient.  Therefore,  the  introduction  of  an  electronic  invoicing 
obligation in Romania requires a derogation from this Article so that the issuer no longer has 
to obtain the consent of the recipient to send an invoice in a paperless format. 

the  field  of  electronic 

law 
invoicing,  Romania  has 
In 
Directive 2014/55/EU  of  the  European Parliament  and  of  the  Council  of  16 April  2014  on 
electronic  invoicing  in  public  procurement2,  which  introduced  an  obligation  for  public 
authorities  to  accept  electronic  invoices  sent  by  their  suppliers.  In  order  to  ensure  the 
interoperability of electronic invoicing systems used in the European Union, starting with the 
public procurement sector, electronic invoices should follow common standards identified in 
CEN  (European  Committee  for  Standardisation)  with  the  European  standard  on  electronic 
invoicing EN 16931. 

into  national 

transposed 

Romania  put  in  place  in  November  2021  the  national  electronic  invoicing  system  RO  e-
Invoice,  created,  developed  and  managed  by  the  Ministry  of  Finance  through  the  National 
Financial Information Centre. According to Romania, this system is fully compatible with the 
European standard on electronic invoicing, and it has been designed and developed to be used 
for electronic  invoicing in  both  public procurement  (B2G) and transactions between taxable 
persons (B2B) should economic operators choose to do so. 

In order to submit invoices via the RO e-Invoice system, both in the B2G relationship and in 
the B2B relationship, taxable persons have to authenticate themselves by using the qualified 
digital  certificate.  This  certificate  is  also  used  for  the  submission  of  the  different  tax 
declarations. 

The RO e-Invoice system will be used as the basis for the implementation of the mandatory e-
invoicing system for transactions between taxable persons. 

The  use  of  the  RO  e-Invoice  system  will  remain  optional  for  non-established  economic 
operators. 

Given the broad scope of the derogation, it is important to assess its impact on taxable persons 
and, more specifically, whether it has contributed to combat VAT fraud and evasion. Should 
Romania  wish  to  prolong  the  derogating  measure,  it  is  requested  to  provide  a  report  on  the 
functioning of the measure together with the prolongation request. This report should provide 
the assessment of the measure on its effectiveness in fighting VAT fraud and evasion and in 
simplifying  tax  collection.  The  report  should  also  include  an  evaluation  of  the  measure  on 

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OJ L 133, 6.5.2014, p. 1. 

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taxable  persons  and  in  particular  what  concerns  the  increase  of  their  administrative  burdens 
and compliance costs.  

It is proposed to authorise the derogation as from 1 January 2024 until 31 December 2026 or 
until  the  date  Member  States  are  to  apply  any  national  provisions  that  they  are  required  to 
adopt  in  the  event  that  a  directive  is  adopted  amending  Directive  2006/112/EC  as  regards 
VAT rules for the digital age, in particular Articles 218 and 232 of that Directive, whichever 
is the earlier. 

• 

Consistency with existing policy provisions in the policy area 

Article  218  of  the  VAT  Directive  puts  paper  and  electronic  invoices  on  equal  footing  by 
providing that Member States shall accept documents or messages on paper or in electronic 
form as invoices. Following Article 232 of the VAT Directive, the use of an electronic invoice 
shall  be  subject  to  acceptance  by  the  recipient.  The  obligatory  electronic  invoicing  as 
envisaged by Romania would indeed derogate from these two provisions.  

The  derogation  can  be  authorised  based  on  Article  395  of  the  VAT  Directive  in  order  to 
simplify  the  procedure  for  collecting  VAT  or  to  prevent  certain  forms  of  tax  evasion  or 
avoidance.  Romania  requested  the  derogating  measure  to  fight  tax  fraud  and  evasion  as  its 
main purpose. Based on the elements provided by Romania, the derogation is consistent with 
the existing policy provisions. 

Similar  authorisations  allowing  Italy,  France  and  Poland  to  derogate  from  Articles  218  and 
232  of  the  VAT  Directive,  in  order  to  implement  mandatory  electronic  invoicing,  were 
granted by Council Implementing Decision (EU) 2021/22513, Council Implementing Decision 
(EU) 2022/1334 and Council Implementing Decision (EU) 2022/10035. 

The Commission adopted in 2020 the “Communication from the Commission to the European 
Parliament  and  the  Council:  an  Action  Plan  for  fair  and  simple  taxation  supporting  the 
recovery  strategy”6.  One  of  the  actions  envisaged  in  this  action  plan  is  the  adoption  by  the 
Commission  of  a  legislative  proposal  aimed  at  modernising  VAT  reporting  obligations.  As 
indicated  in  the  Action  Plan,  this  proposal  should,  amongst  others,  help  streamline  the 
reporting  mechanisms  that  can  be  applied  for  domestic  transactions.  The  need  to  further 
expand e-invoicing will also be examined in this context.  

As a result of this Action Plan, the Commission adopted on 8 December 2022 a Proposal for a 
Council Directive amending Directive 2006/112/EC as regards VAT rules for the digital age7. 
This Directive will amend Article 218 and will delete Article 232 of the VAT Directive. This 
reform,  once  adopted,  will  allow  Member  States  to  implement  mandatory  e-invoicing, 
eliminating  the  need  to  request  further  derogations  from  the  VAT  Directive  in  order  to 
implement such systems. For that reason, once this proposal for a Directive is transposed by 
the  Member  States,  this  Council  Decision  would  no  longer  have  any  useful  effect.  The 
Directive will require that Member States imposing this obligation allow for the issuance of 
electronic invoices which comply with the European standard on electronic invoicing and the 
list of its syntaxes pursuant to Directive 2014/55/EU of the European Parliament and of the 
Council. Further, the issuance of electronic invoices by taxable persons and their transmission 
cannot  be  subject  to  a  prior  mandatory  authorisation  or  verification  by  the  tax  authorities, 

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OJ L 454, 17.12.2021, p. 1. 
OJ L 20, 31.1.2022, p. 272. 
OJ L 168, 27.6.2022, p. 81. 
https://taxation-customs.ec.europa.eu/system/files/2020-07/2020_tax_package_tax_action_plan_en.pdf  
COM/2022/701 final. 

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without  prejudice  to  the  special  measures  authorised  under  Article  395  and  already 
implemented at the time the Directive enters into force. 

While,  according  to  Romania,  the  national  electronic  invoice  system  RO  e-Invoice  is  fully 
compatible with the European standard on electronic invoicing, Romania intends to require, at 
a first stage, that e-invoicing will be carried out mandatorily through a system managed by the 
tax  administration.  Therefore,  suppliers  will  have  to  send  electronic  invoices  to  their 
customers via this system.  

This  will  imply  that  each  electronic  invoice  will  be  automatically  checked  by  the  RO  e-
Invoice  system.  The  system  will  perform  semantic  checks  and  validations  on  structure  and 
syntax.  It  will  also  verify  the  authenticity  of  the  origin  regarding  the  identity  of  the  issuer. 
Once these operations have been performed, an automatic response message is generated.  If 
no  errors  are  identified,  the  electronic  seal  of  the  Ministry  of  Finance  is  applied,  certifying 
receipt of the electronic invoice in the RO e-Invoice system. Only then the electronic invoice 
will be made available to the issuer and the recipient for download. 

As the prior mandatory authorisation or verification by the tax authorities will not be aligned 
with  the  future  system  envisaged  by  the  Proposal  on  VAT  rules  for  the  digital  age  from  1 
January 2028, Romania will introduce the necessary adaptations to its system to allow taxable 
persons, as of 1 January 2026, to send the necessary data through other means outside the RO 
e-Invoice system. Therefore, the authorisation or verification of the electronic invoices by the 
tax authorities will no longer be mandatory. 

Therefore,  the  derogation  asked  by  Romania  is  aligned  with  the  objectives  pursued  by  the 
Commission  as  laid  down  in  the  Action  Plan  and  in  the  Proposal  for  a  Council  Directive 
amending Directive 2006/112/EC as regards VAT rules for the digital age. 

2. 

• 

LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY 

Legal basis 

Article 395 of the VAT Directive.  

• 

Subsidiarity (for non-exclusive competence)  

Considering the provision of the VAT Directive on which the proposal is based, subsidiarity 
principle does not apply.  

• 

Proportionality 

The proposal complies with the proportionality principle for the following reasons.  

The Decision concerns an authorisation granted to a Member State upon its own request and 
does not constitute any obligation.  

The  mandatory  electronic  invoicing  will  entail  a  number  of  changes  for  taxable  persons. 
However,  taxpayers  are  already  familiar  in  Romania  with  the  digitisation  of  their  relations 
with  the tax administration.  The submission  of VAT returns  and other tax returns is  carried 
out by electronic means, through a service provided free of charge by the tax authorities. In 
order  to  use  this  method  of  declaration,  taxpayers  have  a  qualified  electronic  signature 
obtained by means of a digital certificate. 

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The  national  system  for  electronic  invoices,  RO  e-Invoice,  is  already  operational  and 
economic operators have the option to submit electronic invoices via this system, both in the 
B2G and B2B relationships. At the same time, in order to minimise the financial impact of the 
mandatory  implementation  of  the  system,  tax  authorities  will  provide  free  of  charge  an 
application allowing the generation of e-invoices. 

It should be noted that in Romania it is already  obligatory to use electronic invoicing in the 
B2G relationships 
the 
European Parliament  and  of  the  Council  of  16 April  2014  on  electronic  invoicing  in  public 
procurement. 

implementation  of  Directive 2014/55/EU  of 

following 

the 

Romania  considers  that  the  preparatory  work  carried  out  through  the  voluntary  electronic 
invoicing model and the tools that will be put at the disposal of the taxpayers to comply with 
the obligation, coupled with the advantages and benefits derived from the implementation of 
electronic  invoicing,  will  largely  absorb  the  investments  necessary  to  adapt  taxpayers’  IT 
systems. 

The derogation is also limited in time and a report on the functioning and the effectiveness of 
the measure is to be prepared in case Romania wishes to prolong the derogating measure.  

Therefore, the special measure is proportionate to the aim pursued, i.e. to combat tax evasion. 

• 

Choice of the instrument 

Proposed instrument: Council Implementing Decision.  

Under  Article  395  of  the  VAT  Directive,  derogation  from  the  common  VAT  rules  is  only 
possible  upon  authorisation  of  the  Council  acting  unanimously  on  a  proposal  from  the 
Commission. A Council Implementing Decision is the most suitable instrument since it can be 
addressed to an individual Member State.  

3. 

• 

RESULTS 
CONSULTATIONS AND IMPACT ASSESSMENTS 

EX-POST 

EVALUATIONS, 

OF 

STAKEHOLDER 

Impact assessment 

The  mandatory  electronic  invoicing  will  impact  both  the  tax  administration  and  taxable 
persons. 

The implementation of mandatory electronic invoicing is one of the measures included in the 
National Recovery and Resilience Plan. According to Romania, it will reduce the VAT gap by 
a minimum of 5 percentage points by the second quarter of 2026 as compared to 2019. The 
implementation  of  mandatory  electronic  invoicing  will  translate  in  an  increase  of  the 
collection of VAT and direct taxes of at least RON 7.6 billion (around EUR 1.5 billion). 

The  implementation  of  the  digitisation  projects,  such  as  the  RO  e-Invoice  system,  the 
interconnection  of  fiscal  marking  machines,  the  SAF-T,  the  monitoring  of  purchases  and 
deliveries and the RO e-Transport system (monitoring of transport on national territory), will 
allow the integration of risk management. As a result, according to Romanian estimates, the 
collection of additional revenue in GDP will increase in at least 2.5 percentage points by the 
fourth quarter of 2025 compared to the level achieved in 2019. 

The increase in revenue expected to be collected from VAT and direct taxes associated with 
the  implementation  of  the  different  tax  administration  reform  measures,  will  amount  to  a 

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minimum  of  RON 10.87  billion,  5  of  which  will  correspond  to  VAT  revenue  and  5.87  will 
correspond to income from direct taxes. The contribution generated by the implementation of 
the RO e-Invoice system  is  estimated at  approximately 70% of this total  additional revenue 
collected, therefore RON 7.6 billion, from the following sources: 

Increase in voluntary compliance — RON 0.6 billion; 

Reduction of tax evasion and MTIC fraud — RON 1.3 billion 

Reduction of tax optimisation and informal economy — RON 1.6 billion 

Effects  of  direct  taxes  resulting  from  the  re-dimensioning  of  the  VAT  taxable  base  —
RON 4.1 billion. 

Regarding  taxable  persons,  they  will  incur  costs  generated  by  the  acquisition  of  IT  systems 
and/or  software,  as  probably  their  current  systems/software  would  not  be  able  to  issue  and 
submit  electronic  invoices  to  the  RO  e-invoice  system.  However,  such  cost  could  be 
significantly reduced or even eliminated by using the services and applications made available 
free of charge by the tax authorities. 

Economic  operators  will  also  benefit  from  digitalisation  of 
their  processes.  The 
implementation  of  electronic  invoicing  will  entail  faster  payments,  savings  on  transmission 
costs,  fast  and  cheap  processing  of  invoice  data  and  reduced  archiving  costs.  Further,  the 
introduction  of  the  mandatory  electronic  invoicing  system  will  lead  to  the  removal  of  the 
current obligation to report information on domestic supplies. 

4. 

BUDGETARY IMPLICATIONS 

The measure will have no adverse impact on the Union's own resources accruing from VAT. 

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2023/0190 (NLE) 

Proposal for a 

COUNCIL IMPLEMENTING DECISION 

authorising Romania to introduce a special measure derogating from Articles 218 and 
232 of Directive 2006/112/EC on the common system of value added tax 

THE COUNCIL OF THE EUROPEAN UNION, 

Having regard to the Treaty on the Functioning of the European Union,  

Having  regard  to  Council  Directive  2006/112/EC  of  28  November  2006  on  the  common 
system of valued added tax1, and in particular Article 395(1) thereof, 

Having regard to the proposal from the European Commission, 

Whereas: 

(1) 

(2) 

(3) 

(4) 

By  letter  registered  with  the  Commission  on  14  January  2022,  Romania  requested 
authorisation  to  introduce  a  special  measure  derogating  from  Articles  178,  218  and 
232 of Directive 2006/112/EC (‘the special measure’) in order to introduce mandatory 
electronic  invoicing  for  all  transactions  carried  out  between  taxable  persons 
established in the territory of Romania. The authorisation was requested for a period 
from 1 July 2022 to 31 December 2025. 

By letter registered with the Commission 30 September 2022, Romania informed the 
Commission that the requested derogation from Article 178 of Directive 2006/112/EC 
is no longer required. Further, Romania requested the authorisation to be granted for a 
period  from  1  January  2024  to  31  December  2026,  instead  of  the  period  originally 
requested. 

By letters dated 8 December 2022, the Commission  transmitted the request  made by 
Romania  to  the  other  Member  States.  By  letter  dated  9  December  2022,  the 
Commission notified Romania that it had all the information necessary to consider the 
request.  

Romania submits that mandatory electronic invoicing for transactions between taxable 
persons established in Romania, coupled with the obligation to report the data on those 
transactions  to  the  tax  administration,  would  provide  benefits  in  combatting  value 
added tax (VAT) fraud and evasion. It would allow the tax administration to carry out 
a timely and automatic verification of the consistency between the VAT declared and 
paid  and  the  invoices  issued  and  received,  which  would  significantly  improve  the 
analytical capabilities of the Romanian tax administration. Further, the introduction of 
mandatory  electronic  invoicing  would  be  a  powerful  tool  for  real-time  tracking  of 
VAT  fraud  chains,  allowing  tax  authorities  to  take  immediate  action  to  identify  and 
stop traders participating in such fraudulent activities. 

(5) 

Romania  considers  that  the  introduction  of  mandatory  electronic  invoicing  will  also 
benefit  economic  operators  through  digitalisation  of  processes  and  the  reduction  of 
administrative burden, while at the same time ensuring a fair competitive environment 

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for  taxable  persons.  The  digitalisation  of  processes  would  entail  faster  payments, 
savings on transmission costs, fast and cheap processing of invoice data, and reduced 
archiving  costs  for  taxable  persons.  The  introduction  of  the  mandatory  electronic 
invoicing  system  would  lead  to  the  removal  of  the  current  obligation  to  report 
information  on  domestic  supplies,  reducing  the  administrative  burden  for  economic 
operators. 

to 

On  8  December  2022,  the  European  Commission  adopted  a  proposal  for  a  Council 
Directive amending Directive 2006/112/EC as regards VAT rules for the digital age2. 
The proposed amendments will amend Article 218 and delete Article 232 of Directive 
2006/112/EC,  allowing  Member  States 
implement  mandatory  e-invoicing, 
eliminating  the  need  to  request  further  derogations  from  Directive  2006/112/EC  in 
order to implement such systems. Therefore, from the date Member States are to apply 
any national provisions that they are required to adopt in the event that that directive is 
adopted,  this  Decision  would  no  longer  have  any  useful  effect.  Pursuant  to  that 
proposal,  without  prejudice  to  certain  transitional  provisions,  the  transmission  of 
electronic  invoices  will  no  longer  be  subject  to  a  prior  mandatory  authorisation  or 
verification  by  the  tax  authorities.  Romania  intends  to  require,  as  a  first  step,  a 
verification  by  the  tax  administration  of  the  correctness  of  the  invoice  before  the 
electronic  invoice  can  be  considered  valid.  Nevertheless,  Romania  is  to  make  the 
necessary adaptations to the system to allow taxable persons, by 31 December 2025, to 
send the necessary data to the tax administration without the invoice being subject to a 
prior  verification.  As  a  result,  the  prior  verification  of  invoices  by  the  tax 
administration will become optional for taxable persons. 

Given  the  broad  scope  and  the  novelty  of  the  special  measure,  it  is  important  to 
evaluate  its  impact  on  combatting  VAT  fraud  and  evasion  and  on  taxable  persons. 
Therefore,  where  Romania  considers  that  an  extension  of  the  special  measure  is 
necessary, it should submit to the Commission, together with the request for extension, 
a report including the assessment of the special measure concerning its effectiveness in 
fighting VAT fraud and evasion and in simplifying VAT collection. 

The  special  measure  should  not  affect  the  right  of  the  customer  to  receive  paper 
invoices in the case of intra-Community transactions. 

The special measure should be limited in time to allow an appraisal to be carried out of 
whether it is appropriate and effective in light of its objectives. 

(6) 

(7) 

(8) 

(9) 

(10)  The  special  measure  is  therefore  proportionate  to  the  objectives  pursued  since  it  is 
limited in time and scope. In addition, the special measure does not give rise to the risk 
that fraud would shift to other sectors or to other Member States. 

(11)  The  special  measure  will  not  negatively  affect  the  overall  amount  of  tax  revenue 
collected  at  the  stage  of  final  consumption  and  will  have  no  adverse  impact  on  the 
Union’s own resources accruing from VAT, 

HAS ADOPTED THIS DECISION:  

By way of derogation from Article 218 of Directive 2006/112/EC, Romania is authorised to 
accept  invoices  which  have  been  issued  by  taxable  persons  established  in  the  territory  of 

Article 1 

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COM/2022/701 final. 

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Romania  in  the  form  of  documents  or  messages  only  if  those  documents  or  messages  are 
transferred in electronic format. 

Article 2 

By way of derogation from Article 232 of Directive 2006/112/EC,  Romania is authorised to 
provide  that  the  use  of  electronic  invoices  issued  by  taxable  persons  established  in  the 
territory of Romania shall not be subject to an acceptance by the recipient established in the 
territory of Romania. 

Romania  shall  notify  the  national  measures  implementing  the  special  measures  for 
derogations referred to in Articles 1 and 2 to the Commission. 

Article 3 

Article 4 

 1. This Decision shall apply from 1 January 2024 until the earlier of the following two dates: 

(a) 

31 December 2026;  

the date from which Member States are to apply any national provisions that they are 
(b) 
required to adopt in the event that a directive is adopted amending Directive 2006/112/EC as 
regards VAT rules for the digital age,  in particular Articles 218 and 232 of that Directive. 

2. If Romania considers that an extension of the special measure is necessary, Romania shall 
submit a request for extension to the Commission, together with a report assessing the extent 
to which the national measures referred to in Article 3 have been effective in combatting VAT 
fraud and evasion and in simplifying tax collection. That report shall also evaluate the impact 
of those measures on taxable persons and in particular whether those measures increase their 
administrative burdens and costs. 

This Decision is addressed to Romania. 

Done at Brussels, 

Article 5 

For the Council 
The President 

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