Недействителност на актовете за установяване на данъчни задължения при неспазване на срока по чл. 109 ДОПК
Invalidity of acts establishing tax liabilities in cases of non-compliance with the period under art. 109 of TIPC

Summary/Abstract: This Article discusses the terms under the provisions of Article 109 of the Tax-Insurance Procedure Code and the impact that it has on the validity of acts which lay down tax liabilities, but does not claim to be exhaustive. The legal nature of the term is highlighted and an attempt is made to justify the view that its non-compliance results in the invalidity of Acts Revealing Tax Liabilities, due to the violation of three of the requirements for their le- gality – Non-compliance with the administrative and proceedings rules, Violation of time competence rates, and Non-conformity of the Act with the purpose of the law. The practice of the administrative courts and the Supreme Administrative Court is analyzed in this respect.

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