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A query was raised regarding whether the expiry of a tax assessment procedure prevents the initiation of a new one, and whether consultations concerning ongoing procedures are binding. The DGT ruled that consultations regarding procedures already underway are not binding and that expiry does not prevent the initiation of a new procedure, provided the Administration's right to assess has not lapsed.
This ruling clarifies that the expiration of a specific administrative procedure does not preclude the tax authorities from starting a new assessment process, as long as the statutory limitation period for the tax itself has not expired. It also confirms that tax rulings are not binding when they pertain to procedures already in progress.
The tax team reviews your specific situation.
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