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VAT Assessment: Five-Year Limitation, Annual Return, and Supplementary Evidence

  • The court held that VAT assessments based on tax audits must generally be issued within 5 years from the end of the year when the deadline for filing the annual VAT return expires.
  • A 10-year limitation period applies only if the tax authority later receives “supplementary evidence” it could not reasonably have known during the 5-year period.
  • In this case, the 5-year period for the 2011 tax year started on 31.12.2012 and had already expired by the time the disputed acts were served in December 2019.
  • The court found the 10-year period did not apply, because the audit information from the tax enforcement unit reached the tax office in 2017 and could have been used in time.
  • The court accepted the taxpayer’s appeal.

Source: taxheaven.gr

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.



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