Tax authority's first-instance debt determination decision does not interrupt the five-year statute of limitations period.

The Supreme Court dismissed the General Prosecutor's extraordinary revision against a lower court ruling that declared a tax debt statute-barred. The taxpayers had filed a joint declaration for 1994, but the tax office later issued a decision establishing a tax debt and late fees after the five-year limitation period had expired. The court held that merely issuing a declaratory decision by the first-instance tax authority does not interrupt the limitation period; only a first enforcement act notifies the taxpayer and restarts the clock.