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July 17, 2026
Article 25 establishes a statute of limitations on the Tax Authority's power to request documentation. The Authority is prohibited from requesting documents, accounts, books, or asset statements for any tax year that precedes the year of the notice by more than ten years. This 10-year limit provides taxpayers with legal certainty and aligns with the record-keeping requirements under Article 15. It ensures that the Authority cannot initiate inquiries into historical periods that are deemed too remote, thereby protecting businesses from indefinite administrative burdens.
Article 25
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