Article 79 BIS - Statute of Limitations ^{[G68][38][39]}

GTL Notes

^[G68] Deleted by Federal Decree-Law No 16 of 2025 with effect from 1 January 2026. Prior to its deletion, the clause read as follows:

1. Notwithstanding the cases set forth in Clauses (2), (3), (6) and (7) of this Article, the Authority shall not carry out a Tax Audit or issue a Tax Assessment for the Taxable Person following the lapse of (5) five years from the end of the relevant Tax Period.

2. The Authority may carry out a Tax Audit or issue a Tax Assessment for the Taxable Person following the lapse of (5) five years from the end date of the relevant Tax Period, if the same is notified that the procedures of such Tax Audit have been commenced before the lapse of the (5) five years; provided that the Tax Audit shall be carried out or the Tax Assessment shall be issued, as the case may be, within (4) four years from the date of notification of the Tax Audit.

3. The Authority may carry out a Tax Audit or issue a Tax Assessment following the lapse of (5) five years from the end date of the relevant Tax Period if such Tax Audit or the Tax Assessment issuance is related to a Voluntary Disclosure had been provided in the fifth year of the end of the Tax Period; provided that the Tax Audit or the Tax Assessment issuance, as the case may be, is carried out within one year from the date of providing the Voluntary Disclosure.

4. The Cabinet may, at the Minister's proposal, issue a resolution adjusting the time limit specified for completing the Tax Audit or issuing the Tax Assessment, pursuant to Clauses (2) or (3) above.

5. No Voluntary Disclosure may be provided following the lapse of (5) five years from the end date of the relevant Tax Period.

6. In case of Tax Evasion, the Authority may carry out a Tax Audit or issue a Tax Assessment within (15) fifteen years from the end of the Tax Period within which the Tax Evasion occurs.

7. In case of tax registration failure, the Authority may carry out a Tax Audit or issue a Tax Assessment within (15) fifteen years from the date on which the Taxable Person would have been required to proceed with the Tax Registration.

8. The statute of limitations set out in this Article shall be interrupted for any of the reasons set forth in Federal Law No. (5) of 1985, Enacting the Law of Civil Transactions, or any other federal law superseding the same.