VAT supplementary liability decision is accessory to main decision, sharing a five-year statute of limitations.

The Supreme Court dismissed the extraordinary review against a tax authority's decision establishing supplementary VAT liability. The court held that this supplementary decision is legally accessory to the main decision determining the correct refund amount, rather than an autonomous act. Consequently, the five-year limitation period for issuing the supplementary decision runs from the end of the tax year when the main payment deadline expired, rejecting arguments for a shorter three-year limit.