Comunicarea actului administrativ fiscal prin publicitate. Condiţii

Service of the fiscal administrative deed by publication. Conditions

Abstract

The Fiscal Procedure Code does not allow any time limits from the moment when at which the taxpayer requests to be served the appealed procedural document, expressly regulating the steps to be taken for service purposes, with certain consequences on running of the time limit for filing the appeal.

The tax authority, after finding that it was impossible to serve the document in one of the means provided for under art. 44 para. (2) and para. (2¹) of the Fiscal Procedure Code, enforced the subsidiary assumption regulated under art. 44 para. (3) of the Fiscal Procedure Code, in the sense that, as the service was not likely to be carried out by mail, it served the document by publication, by concurrently displaying a notice indicating that the fiscal administrative deed was issued in the name of the taxpayer, at the headquarters of the issuing tax...