ПОГАСИТЕЛНАТА ДАВНОСТ ЗА ДАНЪЧНИ ЗАДЪЛЖЕНИЯ В КОНТЕКСТА НА ПРИНЦИПИТЕ НА ПРАВНА СИГУРНОСТ И ЗАЩИТА НА ОПРАВДАНИТЕ ПРАВНИ ОЧАКВАНИЯ
THE STATUTE OF LIMITATION FOR TAX OBLIGATIONS IN THE CONTEXT OF THE PRINCIPLES OF LEGAL CERTAINTY AND THE PROTECTION OF JUSTIFIED LEGAL EXPECTATIONS

Summary/Abstract: In tax legal theory, it is maintained that as a legal institution, statute of limitations guarantees legal certainty, protects subjects against difficulties of proof, and stimulates the rapid development of legal relations. The first function of the statute of limitations – to guarantee legal certainty – necessitates the question of the legal content of the principle of the same name. The principle of legal certainty is inextricably linked to the principle of protection of justified legal expectations. The boundary between the two principles is blurred and sometimes it is difficult to judge which principle is actually manifesting. Therefore, no attempt is made in the present study to distinguish between the two principles. They are considered together, focusing on their manifestation in EU law and in some European national legal systems.

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