Methodology & legal posture

A per-individual quarterly bundle: receipt photos compiled into a single PDF (facturi), a chronological invoice register CSV (registru cronologic), a formal Romanian-language refund application (cerere de restituire), a self-filer instruction sheet, and an append-only audit log. Format mirrors Anexa 3 and the procedural requirements of OMFP nr. 4146/2015 (Mon. Of. nr. 33/18 ian. 2016), as modified by OMF 1779/2022.

Romanian law (Codul Fiscal art. 294 + OMFP 4146/2015) does not require a consolidated US filer the way Polish law does. Each claimant submits their own cerere de restituire directly to the territorial fiscal authority for their place of stationing — for personnel based at MK Air Base / USAG Black Sea, that is DGRFP Galați.

The bundle this tool produces is filed by you, in person or via the SPV portal, along with proof of SOFA status issued by USAG Black Sea.

Per Codul Fiscal art. 319 alin. (12): a bon fiscal (cash-register receipt) qualifies as a factură simplificată only when the total including VAT is ≤ 100 EUR. Above 100 EUR you need a full factura with your name and address as the buyer.

You can ask any merchant to issue a factura at any amount. They are required to do so on request (art. 319 alin. (20)). Always ask if the purchase is meaningful in size — the 100 EUR threshold is enforced on the recovery side, not at the merchant.

Romania changed VAT rates on 1 August 2025 (Law 141/2025). Standard rate moved from 19% to 21%, and the previous 5% and 9% reduced rates were consolidated into a single 11%. A 9% transitional rate continues to apply for new-housing sales through 31 July 2026.

This tool tracks all five rate slots (21 / 19 / 11 / 9 / 5) so receipts that straddle 1 August 2025 work in a single packet.

The only identifier this tool emits is black_sea_vat_id — a UUID generated when you opt in. Every artifact the tool produces shows this UUID and nothing else.

We hold your receipt photos (with hidden GPS, device, and timestamp metadata stripped both in your browser and on the server), the fields we read from each photo, and your honestmos.com session email (used only to authenticate you). We do not hold your real name, rank, unit, base, EDIPI, DoD ID, family information, bank account, or any other personally identifying field. The mapping from black_sea_vat_id to your real identity is something you control through the SOFA documents you bring with you to ANAF.

The relief is established by Legea nr. 260/2002 (the US-Romania Supplemental SOFA, ratifying the 30 October 2001 agreement) at art. XI, which exempts force members, the civilian component, and dependents from Romanian taxes (including VAT) on personal-use property purchased in Romania.

Implementation lives in Codul Fiscal (Legea nr. 227/2015) art. 294 alin. (1) lit. j)–n) and the procedural OMFP 4146/2015. The 2005 US-Romania Defense Cooperation Agreement extends this to all US forces in Romania, including USAG Black Sea (stood up June 2024).

The packet HonestMOS produces does not include personally identifying documents. ANAF will need to see proof you qualify under SOFA, and you bring those documents with you. Plan to walk into DGRFP Galați / AJFP Constanța with all of the following:

• Your SOFA-status documents — the SOFA card or letter issued by USAG Black Sea Passport & SOFA Services. This is the “you qualify under Law 260/2002 art. XI” evidence. Without it, ANAF cannot confirm your eligibility.
• A passport or ID matching the name on your SOFA documents.
• The signed cerere (printed from this tool) with your bank account (IBAN) and signature filled in.
• The printed registru cronologic and the printed facturi PDF.
• A pen. ANAF clerks may ask you to initial the registru pages or sign additional declarations on the spot.

The self-filer cover sheet inside the packet has the full checklist with the relevant legal citations — print it and bring that too.

• Hidden GPS, camera, and timestamp metadata inside receipt photos is scrubbed in your browser AND re-scrubbed on the server.
• Photos and generated artifacts live in private storage buckets with self-only access policies.
• IP addresses are hashed with a daily-rotating salt before being written to the audit log; raw IPs are never stored.
• The audit log is append-only by database policy.
• Per-user dedup is enforced via SHA-256 of the stripped image bytes.

• Submit anything to ANAF on your behalf.
• Hold or transmit your real name, rank, unit, base, EDIPI, DoD ID, or banking information.
• Aggregate your bundle with other claimants’ bundles.
• Determine the refund disbursement back to you (that’s ANAF’s decision after they review your file).