“Tax voucher” as a ratio for the interruption of the write-off period as regards the State’s right to impose taxes
Published in “Theory & Practise of Administrative Law”, January 2018, No. Issue 103
By the latest decisions of the Council of State as regards the write-off period of the State’s right to levy income tax and notify the relevant tax voucher notices, the constitutional principles of legal certainty, predictability (as a specific form of legal certainty) and proportionality were highlighted as important matters of tax law.
In the light of the aforementioned case-law, a strong concern pertinent to the constitutionality of the provisions on the interruption of the write-off period, stipulated in Article 36 par. 1 of Law 4174/2013 in conjunction with article 72 par. 11 of Law 4174/2013, has arisen.