On 24 September 2026, the Supreme Court confirmed that the Tax Inspection can verify the origin and amount of VAT credit balances generated in prescribed (time-barred) periods if those balances have been carried forward and used to offset VAT due in non-prescribed periods. The ruling (Sentence 987/2026) establishes that while the Tax Agency cannot directly assess a prescribed period, it can examine the source of a credit balance that is being actively used in a current, open tax period. This effectively extends the verification power beyond the standard four-year statute of limitations for VAT.
Key Takeaways
- Extended Verification Reach: Tax inspectors can audit VAT balances originating up to ten years ago if they are still being utilized in current returns.
- Record Retention Critical: Taxpayers must retain complete VAT records, including invoices and ledgers, for as long as the related credit balances remain in use.
- Strategic Compliance: Businesses should regularly reconcile carried-forward VAT credits and ensure they can substantiate the origin of each balance.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement