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A query is made as to whether the submission of the annual VAT summary return (Form 390) interrupts the statute of limitations for the Administration to determine the tax liability. The DGT responds in the affirmative, based on the doctrine of the Supreme Court.
Question posed: Whether the filing of Form 390 interrupts the statute of limitations of the Administration's right to determine the tax liability.
The filing of Form 390 interrupts the statute of limitations of the Administration's right to determine the tax liability. This is because said filing constitutes a reliable action by the taxpayer leading to the assessment or self-assessment of the debt, as established in the General Tax Law and the doctrine of the Supreme Court.
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