At the end of 2022, a new law was adopted reforming the review and prescription periods for collection in relation to VAT.
Historically, the period was 3 years. It was moved to 4 years in the case of late filing or non-filing of declarations for both VAT and direct tax.
In the case fraud or suspected fraud, the period was seven years. It is now moved to 10 years.
Also in the past, the tax office agent would rely on strong evidence to trigger the time period.
Since the end of 2022, simply the presumption of fraud is sufficient to trigger the time period.
And to top it off, the definition of fraud will be left to the sole discretion of the tax office…
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