Court allows tax appeal, ruling that notification to the split-off company cures the statute of limitations for the successor entity.

The Court of Cassation allowed the tax authority's appeal against the Regional Tax Commission's dismissal, overturning the lower court's decision. The authority argued the statute of limitations had expired because the tax notice was sent to the successor company years after the corporate split. The court ruled that a timely notice to the original split-off company validly interrupts the limitation period, rendering the subsequent notice to the successor entity unnecessary and preventing the authority from losing its right to collect.