Thousands of tax cases were barred for the years from 2005 to 2015, which the Tax Office did not manage to send the audit notes in time and can no longer control them.
The right of AADE to control them was also barred movements of bank deposits for the year 2015 (and previous years) as the five-year period expired in which he had the opportunity to control them and cross them with the declared income.
In particular, taxpayers who did not receive a checklist or settlement note, until December 11th for their tax arrears years 2015, 2012, 2010 and 2005, they have no reason to be afraid as the tax authorities can not reopen these cases.
For cases expired on 31 December 2021 the tax audit services had to send by December 11th the administrative determination of the tax, so that the taxpayers have a 20-day period to express their objections and to finalize the tax liability.
You will also need the checklist be issued and notified to the taxpayer within the deadline limitation period. These two parameters mean that thousands of tax cases are statute-barred.
It is stressed, however, that they are excluded from the statute of limitations and the cases can be opened before 2015, if they arise “additional information.
Complementary are those facts, which could not have been known by Tax office, within the five years which is the general rule of limitation of tax cases. If any of them are identified, such as one fake or fictitious invoice, the case is reopened and the limitation period extends to a decade.
However, in the category of “supplementary data” do not fall into bank deposits, following court rulings, which ruled that the movements of bank accounts could be controlled by the Tax Office within five years.
This means that the Tax Office even if it finds one suspicious bank account transaction recorded in 2015, can not conduct a tax audit and certify taxes, fines and surcharges.
Which cases were barred?
The cases that are now barred are the following categories: