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May 15, 2026

This Article outlines the statutory periods for tax assessments and refunds. The Department may issue or amend a tax assessment within five years of the tax declaration deadline, provided a reasoned notification is given. This period can be extended indefinitely with the taxpayer's written consent. For cases involving non-filing or the submission of an incomplete or incorrect declaration with intent to evade tax, the assessment period is extended to ten years. Conversely, a taxpayer is permitted to request a refund for any overpaid tax within five years from the end of the taxable year in which the overpayment occurred.

Chapter 12 - Filing of Declarations, Assessments, Procedures of Objections, and Appeals

Article 65 - Statutory Period of Tax Assessment

The Department may, with a reasoned notification, make or amend a tax assessment within five years of the deadline specified for filing the tax declaration for the taxable year, or at any time, upon the written consent of the taxpayer.
The Department may make or amend an assessment within 10 years of the deadline specified for filing the tax declaration for the taxable year if a taxpayer does not file its tax declaration, or it is found that the declaration is incomplete or incorrect with the intent of tax evasion.
A taxpayer may request a refund of overpaid amounts at any time within five years from the end of the taxable year in which the amounts were overpaid.