Resolution of the Supreme Administrative Court (NSA) on limitation periods for tax liabilities suspended under COVID regulations
On 27 March 2023 the Supreme Administrative Court composed of seven justices adopted an important resolution concerning applicability of COVID legislation to tax matters. The subject matter was suspension of the limitation period for tax liabilities under Art. 15zzr(1)(3) of the COVID-19 Act of 2 March 2020. These provisions, if interpreted unfavorably, could result in extension of the limitation period by 72 days. The NSA answered the question whether the disputable provisions were also applicable to the periods prescribed by the tax law.