STATUTE OF LIMITATIONS - ON IMPLEMENTATION OF CIVIL LEGAL RULES IN THE TAX LAW AND COURT PRACTICE

The statute of limitations contributes to legal security of parties involved in legal relations being implemented in the field of private and public law. In principle, the statute of limitations has been considered as an institute of the Civil Law. Therefore, it is no surprise that revenue regulations prescribe a subsidiary application of the Civil Law regulations on statute of limitations. Nevertheless, there are considerable and significant differences between the statute of limitations in Civil Law and in Tax Law. The practice has confirmed these differences. Having this in mind, the author concludes that Civil Law rules governing the statute of limitations can be exceptionally implemented in revenue operations and court practice. If otherwise, legal security would be jeopardized.