Correction of tax liabilties by the tax authority

The Dutch tax liability formalization procedure has not undergone relevant statutory changes for 60 years. During that time, however, the introduction of computers and data analysis tools (among other developments) have changed the way the formalization process takes place in practice. These practical changes materially change the legal protection of taxpayers against additional tax assessments. My research explores ways to update the legal protection to the 21st century.

When should the tax authority be allowed to increase your tax liabilities in the years following a taxable event? Currently the rules governing additional tax asessments are fully dependent on a distinction between two types of taxes. That distinction has lost much of its meaning. My research aims at finding new relevant circumstances that should determine when the tax authority should (not) be allowed to increase old tax liabilities.