This article was first published in our monthly newsletter Indirect Tax News. This newsletter sums up the main news in indirect tax and customs.
The tax authorities’ extended statute of limitations concerning hidden activity (10 years) cannot be replaced by the standard statute of limitations when the foreign entity’s VAT returns were not submitted for the same professional activity as the one who led to an audit of the tax authorities.
In this particular case, the entity had submitted VAT returns but for another activity as the one being qualified as hidden.