Commencement/ Re-commencement of statutory terms in tax proceeding

On 24th May 2020, statutory terms will commence or recommence (depending on whether the decision, sentence, summons, etc., were delivered before or after 14 March 2020) in the following proceedings:

• tax audits,
• customs and tax audits,
• proceedings held pursuant to the Tax Code (e.g. for an advance tax ruling),
• administrative court proceedings.

This is because on 16th May the so-called Shield 3.0, pursuant to which the existing provisions regarding suspension or non-commencement of statutory terms for these type of tax proceedings were repealed, came into force.
According to the above-mentioned law, statutory terms for tax matters will recommence or commence after 7 days from the effective date of Shield 3.0 – i.e. from 24th May 2020.

Therefore, if you have received an unfavourable decision, advance tax ruling, or have been served with a request to submit documents – it will be necessary to take action despite the instructions included in the letters served (informing about the suspension of statutory terms until the end of the state of epidemic/epidemic threat).