Extended limitation period – notification of indications of fraud

When the VAT administration intends to apply the limitation period of 7 years (and 10 years, in certain circumstances, on 01/01/2023), it must first notify the indications of fraud to the taxable person under penalty of nullity ( art. 81bis and 84ter VAT).

The question has arisen as to what these indices should consist of. It should not be an absolute proof or even conversely a supposition.

The Antwerp Court of Appeal recently ruled on the subject.

Source Aurelie Soldai

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