CHANGES IN THE STATUTE OF LIMITATIONS FOR ASSESSMENT AND COLLECTION OF TAX RETURNS
The Tax Administration now has broader terms to exercise its audit powers over taxpayers
The new regulation extended the statute of limitation from two (2) years to three (3) years, computed since:
- The due date to file the tax return;
- The filing date of the tax return, when it was filed extemporaneously;
- The date of the request for a balance in favor; and
- The use of the balance in favor in subsequent tax periods.
In the same way, the new tax regulation extended the statute of limitation of the tax returns that report NOL’s from five (5) years to six (6) years since the submission date.
For taxpayers obliged to file transfer pricing returns, the statute of limitation will be six (6) years since the due date, or the submission date, in the cases in which it was submitted extemporaneously.