When a company becomes subject to a tax inspection, it must adhere to two different types of deadlines: response deadlines for specific requests and the overall timeframe for the inspection process. While businesses are typically required to respond to tax authority requests within 10 or 15 business days or, in certain cases, one month, the overall duration of the inspection process is significantly longer. Understanding these deadlines is essential for effective compliance and strategic tax management.
Overall timeframe for tax inspections: 18 or 27 months
In general, an inspection must be completed within 18 months, calculated from the date the authorities notify the company of the initiation of proceedings. This means that if an inspection begins on 25 May 2024, the resolution must be issued by 25 November 2025.
However, this period extends to 27 months in specific cases, such as when the company’s annual turnover equals or exceeds €5.7 million or when it forms part of a corporate tax consolidation group or a VAT group under inspection.
The tax authorities are considered to have met the deadline as long as the resolution is formally notified within this period. In the case of paper notifications, it is sufficient that a delivery attempt has been made within the deadline. For electronic notifications, the resolution is deemed notified as soon as it is made available in the company’s electronic inbox, even if it has not yet been accessed.
Circumstances that may extend the inspection period
Although the law establishes clear time limits, certain situations may extend the total duration of the inspection:
- Suspension of proceedings: If the process is temporarily halted—for example, due to referral to the Public Prosecutor’s Office, submission to a consultative commission, or force majeure—the timeframe is paused and resumes once the proceedings continue.
- Courtesy period: Businesses may request up to 60 days during which tax authorities cannot conduct inspection activities. These days are then added to the total timeframe, effectively extending the deadline.
- Delayed submission of documentation: If the company does not provide the requested documents on time because these were not available, the inspection period may be extended: If the documents are submitted more than nine months after the inspection begins, the deadline is extended by three months. If they are provided only after the inspection report (acta) has been issued, being necessary additional investigative measures, the period is extended by six months.
