In a recent judgment, the Supreme Tax Court decided that a participant in tax evasion - here: as assistant - cannot be held liable through a notice of liability. The exception from the exemption from liability as provided in Section 191 (5) Sentence 2 of the General Tax Code in cases where the tax assessed is statute-barred applies only to those who have personally committed tax evasion or tax fraud.
The Supreme Tax Court has confirmed that the maximum foreign income limit for the option to treat a non-resident spouse as taxable does not apply within the EU.