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The applicant inquired whether requesting an extension to submit Inheritance Tax documentation after the deadline could interrupt the Administration's statute of limitations. The Directorate-General for Taxes (DGT) ruled that any request submitted after the initial five-month period is deemed inadmissible and has no legal effect; therefore, it neither postpones the start of the calculation period nor interrupts the statute of limitations.
Question posed The inquiry raises the following question:
Requests for an extension submitted after the first five months of the submission period are considered inadmissible and produce no effect. Consequently, they do not postpone the commencement of the calculation period for the statute of limitations regarding the power to assess tax. Furthermore, requests for an extension cannot be grounds for interrupting the statute of limitations, as a period can only be interrupted once it has already commenced.
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