How does a tax inspection proceed and how long can it last?

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During a tax inspection, the Inspectorate may carry out the verification and investigation activities covered by the stated scope and request relevant information and documents. The taxpayer is informed of the actions and their continuation under the General Tax Act (LGT) and its implementing rules. A break between working sessions, or a period with no activity, does not by itself trigger a general six-month interruption rule.

Duration. Under section 150 LGT, the maximum period is 18 months in general and 27 months in specified cases, including when annual turnover reaches the statutory audit threshold, the taxpayer is part of a tax-consolidated group or VAT group under inspection, or the procedure concerns the Minimum Tax. The period runs from notification of commencement until notification, or a valid attempt to notify, the final administrative act.

The time limit is suspended only in the circumstances listed in section 150(3) LGT, including certain referrals to judicial bodies, arbitration conflicts, referrals to the Advisory Committee, and force majeure. The general exclusions for justified interruptions or delays not attributable to the Administration under section 104(2) LGT do not apply to the inspection time limit.

Before the hearing stage opens, the taxpayer may request one or more periods during which the Inspectorate will not act with them. Together these periods may not exceed 60 calendar days and extend the maximum duration; the implementing Regulation sets additional conditions, including a minimum of seven calendar days for each requested period.

If the time limit is exceeded. The procedure does not automatically lapse; it continues until completion. However, inspection actions taken within the exceeded time limit do not interrupt the limitation period. A later action may interrupt it subject to statutory requirements, and the taxpayer is entitled to be informed of the tax concepts and periods covered. Payments allocated to the inspected tax and period, made from commencement until the first action after the time limit is exceeded, are treated as spontaneous for the purposes of section 27 LGT.

The rules must be applied to the facts and procedural history of each case. Proceedings started before 12 October 2015 may be subject to transitional provisions and the rules applicable on their commencement date.

Legal sources: section 150 LGT and section 184 of the General Regulation on tax management and inspection procedures.