- The case concerns a tax account booking for VAT 2011 after a self-disclosure and later annulment of the reassessment due to absolute limitation (statute of limitations).
- In 2017, the taxpayer filed a self-disclosure for 2010/2011 and paid €2,362,954.28 in additional VAT.
- In 2021, the tax office reopened the VAT 2011 proceedings and booked the additional assessment, but the Federal Finance Court later annulled that reopening and the new assessment in 2024 because the claim was absolutely time-barred.
- After the annulment, the tax office made a new booking on 29 October 2024, which the taxpayer challenged via an accounting statement request.
- The Federal Administrative Court set aside the Federal Finance Court’s decision, holding that it was unlawful in substance.
Source: ris.bka.gv.at
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.
