On 1 July 2019, the tax authority published the Circular E.2123 explaining the application of the limitation period in the event of late filing of a tax return. The new Circular amends Circular 1165/2018 in relation to the limitation period of 15 years which applies to the late filing of a tax return after the expiry of the original limitation period of 5 years.
In particular, the Circular 1165/2018 was amended as regards the application of the 15-year limitation period in the event of late submission after five years. Further, it is clarified that in the event of a late submission after the initial limitation period of five years, the fifteen-year limitation period, but a shorter three-year period, starting from the end of the year of submission of the late submission and not exceeding fifteen years, shall not apply.
Therefore, for any late income tax returns filed in the 13th, 14th or 15th year after the deadline for their submission, there is no question of further extension of the 15-year limitation period.
