The objection of limitation may be exercised at any time by the tax proceedings, including in the appeal proceedings of the tax audit act. The objection to expiration of prescription is extinguished, ie it is no longer due. The tax audit act can only establish existing and enforceable public obligations, but not on different legal bases and therefore undue amounts.
The expired limitation period expires the debt and the possibility that it will be forcibly collected. The limitation period is a time limit or a period of time determined by the law, during which, if the creditor fails to act, his entitlement to enforcement is extinguished.
The only possibility for the expiry of compulsory enforcement is the abolition of the tax audit act, which establishes the extinction of public receivables. The legal theory has expressed opinions protecting the official application of the limitation period for tax obligations.