Supreme Court dismisses appeal as statute of limitations issue exceeds scope of tax liability decision review.
Pologne (PL)
Synthèse Legislator
Généré par l'IAThe Supreme Court dismissed the cassation appeal regarding the statute of limitations for a third-party tax liability decision. The procedural scope was limited to verifying the legality of the Social Insurance Institution's decision on the manager's liability, not the expiration of the obligation itself. The court ruled that the statute of limitations question only arises during enforcement proceedings after the liability decision becomes final, thus falling outside the administrative appeal's subject matter.
Regeste Legislator
Généré par l'IAArt. 118 § 2 Ordynacji podatkowej; art. 24 ust. 5d ustawy o systemie ubezpieczeń społecznych: The statute of limitations for a third-party liability obligation does not constitute an element of the legal relationship subject to a decision establishing such liability and must be examined only during enforcement proceedings.