Administrative Court RulingsTax lawTax LitigationInstrumental initiation of tax criminal proceedings – an ineffective way to suspend the tax limitation period
March 16, 2026
In February 2026, an administrative court examined whether tax authorities can initiate fiscal penal proceedings solely to suspend the statute of limitations for tax liabilities. The ruling confirmed that when such proceedings are initiated for purely instrumental purposes, they do not produce legal effects and cannot suspend the tax limitation period.
