VAT overpayment interest denied because tax debt only arises upon tax authority's failure to refund within statutory terms.

The Supreme Court dismissed the taxpayer's appeal regarding interest on overpaid VAT, upholding the tax authority's decision to reduce the debt amount. The taxpayer argued that overpayments occurred monthly due to declaration errors, but the court held that legal consequences for overpayment depend solely on the tax authority's failure to refund the difference within the statutory period. Consequently, the court ruled that interest is only due if the tax office does not fulfill its obligation to return the difference by the deadline specified in the tax code.