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Tax audits, invitations to explain and settlement

Invitation to explain, tax audits, VAT refund audits, preliminary findings of fake invoices, penalty reduction, settlement and litigation; deadlines, outcomes and a preparation plan.

Última actualización: 21 de octubre de 2026

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A letter from the tax administration does not always mean a penalty, but deadlines are short and the quality of the first reply shapes the outcome. Forwarding the letter the day you receive it keeps all options open.

Which letter did you receive?

Letter Meaning Deadline
Invitation to explain (art. 370) The administration found an inconsistency (preliminary finding); a chance to explain or correct before an audit 30 days from notification
Request for information (art. 148) Request for information and documents on a topic As stated (usually 15 days)
Audit letter / request for books A tax inspector's audit has begun As stated; full audits usually within 1 year, limited audits within 6 months
Tax / penalty notice An assessment has been made 30 days: settlement, art. 376 reduction or lawsuit
Payment order Notice of a final debt 15 days

Via e-Notification, a letter is deemed served at the end of the fifth day after it reaches the electronic address.

Invitation to explain

  • Scope: art. 370/a general preliminary findings; 370/b preliminary findings of using fake or misleading documents (in 2026 with an amount threshold and 5% of annual purchases). Evasion acts are generally excluded.
  • If the explanation is accepted: no audit or assessment referral for the finding. The commission decides on a timely explanation within 45 days at the latest.
  • If it is not sufficient: the under-declaration is corrected within 30 days of the result and the tax is paid with a surcharge; the tax loss penalty is 20%.
  • If there is no reply: referral to audit or assessment; penalties without reduction.
  • As the finding is known to the administration, voluntary disclosure is no longer possible.

30-day preparation plan

Day Work
0–2 Confirm notification date, letter type, period and amount
3–7 Collect books, returns, e-documents, bank and contract records
8–14 Reconcile the finding with records line by line
15–20 Assess whether tax was lost and the filing options
21–27 Draft the explanation with numbered annexes; cross-check with a lawyer
Before day 28 Submit via the Digital Tax Office and keep the receipt

During an audit

  • Reply on time; produce books and documents completely (books not produced lead to estimated assessment and severe consequences).
  • Check the minutes of meetings with the inspector; have points in the taxpayer's favour recorded.
  • In VAT refund audits, contest counterparty findings and submit documents.

Three routes after assessment

Route When suitable
Penalty reduction (art. 376) If the finding is correct; tax loss penalty reduced by 1/2 the first time, 1/3 thereafter, irregularity by 1/2. Payment within 30 days
Settlement If the amount or penalty is disputable; the settled amount is final, no lawsuit
Litigation If there is a legal disagreement; tax court within 30 days

Details and examples: Tax penalties and voluntary disclosure · Tax loss penalty calculator · Late payment interest

Common mistakes

  • Not checking the e-Notification box and missing the deadline.
  • Replying to an invitation with general statements and no documents.
  • Trying voluntary disclosure after an audit has started.
  • Planning settlement and the art. 376 reduction at the same time (choose one).

Sources

Tax Procedure Law No. 213 (art. 107/A e-notification, arts. 134–141 audits, art. 148 information requests, art. 370 invitation to explain, art. 371 voluntary disclosure, art. 376 reduction, additional arts. 1–12 settlement); Tax Procedure Law Communiqué No. 519; Tax Inspection Board guide on invitations to explain; Law No. 6183 art. 55 (payment order).