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Enforcement in tax matters versus enforcement in the civil procedure. Role of the revenue agent in the relationship with the taxpayer

The institution of enforcement is important both for the creditors – individuals and legal entities, as well as for the tax creditor, since it guarantees the judicial power of the obligations. Considering the features of the tax debt instrument as compared to other debt instruments, in case of enforcement of tax debs, contrary to the common law, we have a special procedure regulated by the Code of tax procedure, which shall be supplemented, where this regulation does not dispose, with the provisions of the Code of civil procedure in the matter, insofar as they comply with or do not breach the special rules of the tax law. The enforcement shall be made by the relevant enforcement body, through the agency of the revenue agent, a concept which is not defined in the present code, but which however, was granted a definition in the new Code of Tax Procedure. This article comparatively describes several common issues regarding the enforcement regulated by the present Code of Civil Procedure and by the Code of Tax Procedure, emphasizing, at the same time, the similarities and differences between the role of the revenue agent and that of the bailiff.