Tax evasion is generally time-barred after 10 years, reckless tax evasion (i.e. without intent) after 5 years. However, the limitation period only begins at the end of the year in which a tax return was submitted. If no tax return has been submitted, the limitation period only begins after 3 years, i.e. the tax office can go back up to 13 years in such a case.
For foreign investment income from non-EU countries, there is also a suspension of the limitation period if there is no agreement on the automatic exchange of information in tax matters (TIEA) with the country in question. This means that the above-mentioned limitation period only begins when the tax authorities become aware of it, but no later than 10 years after the end of the calendar year in which the tax arose. This means that taxes on such foreign income can still be assessed retroactively for up to 20 years. As investors generally do not keep records of the income earned for this long, nor do the retention periods at most banks extend back this far, estimates must generally be made, which are always at the expense of the taxpayer. If he estimates too high, he has to pay more tax. If the estimate is too low, there is a risk that the voluntary disclosure will not be recognized overall.
You can read about the consequences of tax evasion here.
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