Abstract

The statute of limitations for a fiscal offence is closely related to the expiration of the public law receivable the offence refers to. The time limit starts on the date of the commitment of the offence, though the Penal Fiscal Code provides for exceptions from that rule. The limitation for punishability of a fiscal offence rests if the statute does not allow for initiating or continuing penal proceedings, and it may also be prolonged upon initiation of penal proceedings against the offender.

The Penal Fiscal Code stipulates that the limitation period for punishability of a fiscal offence starts anew if the final decision is reversed. This solution may lead to non-limitation of fiscal offences.