Interest Due under Article 19 of the Tax and Insurance Procedure Code

Authors:

Pages: 79-83
DOI: https://doi.org/10.54664/YHXW5228

Abstract:

A special case of personal liability of the management of taxable legal entities has been created through the provisions of Article 19 of the Tax and Insurance Procedure Code (TIPC). Following the amendments to the aforementioned legal provisions, which have come into force on 4 August and 21 November 2017, the subjective scope of the liability under Article 19 of the TIPC has been significantly expanded as it currently covers the majority owners of the taxable person’s capital and, in certain situations, the shareholders holding minority shares. In relation to the increasing number of tax audit proceedings focusing on the realization of the liability under Article 19 of the TIPC, and the expanding case law on the application of the above-mentioned legal provisions, the scope of Article 19 of the TIPC requires a more detailed analysis, particularly of the interest due.

Keywords:

taxes, interest, liability, Article 19 of the TIPC, tax audit

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