Art. 151 Tax Law (TL)

1 The right to conduct taxation is subject to a statute of limitations of five years from the end of the fiscal year.

2 The limitation period does not commence or is suspended

a) during proceedings for claims, appeals, or revisions;

b) as long as the tax debt is secured by guarantees or its collection is deferred;

c) as long as the taxpayer or a person jointly liable with them for the tax payment does not have a domicile or is not residing in Switzerland.

3 A new limitation period begins to run

a) when the authority takes a measure aiming to establish or assert the tax debt and informs the taxpayer or a person jointly liable with them for the tax payment;

b) when the taxpayer or a person jointly liable with them expressly acknowledges the tax debt;

c) when a criminal prosecution is initiated following consummated tax evasion or a tax offense.

4 The statute of limitations for the right to conduct taxation expires in any case 15 years after the end of the fiscal year.

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