When do the Fiscal Authorities right to assess tax liabilities begin its statute of limitation?
The statute of limitation of the right of the fiscal body to assess tax liabilities begins as of 1st January of the year following the year when the tax receivable arose according to art. 23 of the Governent Ordinance no. 92/2003, republished, unless otherwise provided by law. The right to assess tax liabilities shall be limited to 10 years, however, when such liabilities result from a criminal law violation committed as provided by the criminal law. This term begins as of the date of committing the fact that it is a criminal law violation and it is to be sanctioned as such by a final court decision.
Also, it is advisable that you know the following legal provisions:
- for the large taxpayers, the period subject to tax audit begins as of the end of the period which was previously audited;
- for the other categories of taxpayers, the tax audit is carried out upon the receivables arisen within the last three fiscal years for which there is an obligation to submit tax statements.
