AADE accelerates tax audits ahead of 2026 statute of limitations

The Independent Authority for Public Revenue (AADE) is accelerating tax audits to prevent cases from reaching their statute of limitations at the end of 2026. This shift follows a decision by the Council of State (StE) regarding the unconstitutionality of 10-year and 20-year statute of limitations, effectively reinstating the standard five-year rule.

Tax authorities are prioritizing files related to income tax and VAT, particularly from the 2020 tax year. For income and VAT declarations submitted by the end of 2024 for the 2020 tax year, the five-year period expires on December 31, 2026. To prevent these cases from being permanently closed due to expiration, the administration must not only initiate audits but also complete the procedures and officially notify taxpayers of tax assessments and penalties within the legal timeframe.