§ 223 Tax Act (StG)

1. Prosecution for completed tax evasion becomes statute-barred ten years after the end of the tax period for which the taxable person was either not assessed or incompletely assessed, or the withholding tax was not lawfully executed, or ten years after the end of the calendar year in which an unlawful refund or an unjustified remission was obtained or estate values were concealed or removed during inventory proceedings.

2. Prosecution for attempted tax evasion becomes statute-barred six years after the final legal conclusion of the proceedings in which the attempt to evade taxes was made.

3. The statute of limitations no longer applies if the competent authority has issued a ruling before the expiration of the limitation period.

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