The presence of uncertainty in the timing of a tax audit often leads to a violation of taxpayers’ rights.
The tax inspectorate has the right to verify the concluded transaction within two years. And taxpayers have the right to clarify information about the transaction. In this regard, there is a misunderstanding at what point the two-year period begins to flow.
If there are errors in the notification, the taxpayer may submit an updated notification to correct it. But the deadline for conducting an inspection cannot be counted from the date of receipt of the specified notification, as this violates constitutional rights.
Based on the decision of the Constitutional Court, the moment of the beginning of the calculation of the deadline is the submission of a notification to clarify the information.