Generally, the right to assess a taxpayer in relation to corporate income and capital taxes expires five years after the end of the corresponding tax period. Under certain conditions (eg, where the relative statute of limitations is interrupted), the absolute statute of limitations of 15 years applies. In cases of tax fraud or tax evasion, finally assessed tax periods can be reopened.
Request for rectification
The taxpayer may generally not challenge immediately their assessment in court. Rather, within 30 days of its notification, the taxpayer may turn to the tax authority that issued the tax
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