The New Union Tax Credit Collection Model

a Critical Analysis on Advantages and Retrocesses of New Institutes Created by PGFN Ordinance No. 33/2018

Abstract

The aim of this paper is to analyze the changes made by Ordinance no. 33/2018 in the tax process, focusing on the institutes of the prior legality examination, the request for registered debt revision (PRDI), the offer of advance guarantee and the pre-registration executive. The research problem is whether the reforms promoted by the regulation can be considered favorable or unfavorable to the taxpayer. In the pre-execution annotation approach, it will also be asked whether it should be qualified as an indirect means of tax collection or as a way of ensuring the effectiveness of the tax process. Through bibliographic methodology, qualitative approach and critical analysis, it is concluded that the new tax legislation under review promoted important advances when it established the PRDI and the early offer of guarantee, having, however, set back and violated the taxpayers fundamental rights regarding the subject of the pre-execution annotation.