Judgment of the Court of Cassation dated July 19, 2024
The Court of Cassation issued a ruling last Friday regarding the starting point of the statute of limitations for liability claims arising from tax advice.
In particular, it notes that "in tax matters, it is held that the loss is not realized and that the statute of limitations has not begun to run until the outcome of the disputed claims is definitively known, or that the loss resulting from a tax assessment is realized only on the date the appeal is dismissed by the tax court."