Evidence collection to determine carousel transaction vs the lengthiness of proceedings – a few remarks as exemplified by vat refund

Abstract

The length of tax proceedings can be justified by the necessity to conduct a lot of evidence activities from numerous entities taking part in chain transactions. At the same time, the length of the proceedings is not always tantamount to its lengthiness. This is particularly visible in the case of evidence collection to determine carousel transactions, where the tax authorities have both an opportunity and obligation to check the correctness of the tax due, input tax and excess tax refund calculated and declared by the taxpayer. The objective of this paper is to discuss the lengthiness of the tax proceedings in the context of evidence collection by the tax authorities to determine carousel transactions.