Article 25 establishes a statute of limitations on the Tax Authority's power to request documentation. The Authority is prohibited from requesting documents, accounts, books, or asset statements for any tax year that precedes the year of the notice by more than ten years. This 10-year limit provides taxpayers with legal certainty and aligns with the record-keeping requirements under Article 15. It ensures that the Authority cannot initiate inquiries into historical periods that are deemed too remote, thereby protecting businesses from indefinite administrative burdens.
Part 2 - The Tax Administration
Chapter 1 - The Authority
Article 25
[GTL Notes: Limitation on Information Requests]
The Authority may not request the submission of any documents, information, accounts, books of accounts or statements of assets or liabilities relating to tax liability of any person for a tax year which precedes the tax year in which the notice is addressed by more than ten years.
Continue Reading
Access Full Content
You're viewing a preview of this document. Please log in to unlock the complete content, annotations, and research tools.