On 28 September 2026, the State Tax Inspectorate (VMI) issued an informational notice supplementing the consolidated explanations (comments) on Articles 13, 401, and 68 of the Law on Tax Administration (MAĮ). Acting under Article 12 of the MAĮ, the VMI clarified procedural aspects of tax audits, taxpayer appeal rights, and the statute of limitations for tax assessments. The guidance addresses practical ambiguities identified during recent audit cycles, particularly regarding the initiation of tax checks, the scope of document requests, and the calculation of interest on tax arrears. The comments carry interpretive weight for both tax officials and taxpayers, though they do not create new legal obligations.
Key Takeaways
- Audit Initiation Clarity: The guidance specifies that tax audits may only commence after a formal written notice delivered via the eVMI portal or registered mail, with a minimum 10-business-day advance period, protecting taxpayers from surprise inspections.
- Document Request Limits: Tax officers are restricted to requesting documents directly relevant to the audit scope; blanket demands for entire accounting archives are prohibited unless justified by suspected fraud.
- Interest Calculation Method: Interest on tax arrears accrues from the day after the statutory payment deadline until the date of actual payment, using the European Central Bank reference rate plus 2 percentage points, updated semi-annually.
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