Decision No. 125/1 issued by the Ministry of Finance on 11/03/2019 and published in the Official Gazette on March 14, 2013 (here below) has set the commencement date of the limitation period (statute of limitation) applicable to the administration, according to Article 43 of the Code of Tax Procedures (Law No. 44 of 11/11/2008 and its amendments) to recover the rights and liabilities of the Public Treasury (tax adjustment), as of the occurrence of the generator event. It is fixed for corporations and enterprises as to their annual income to the year in which the event or fact has occurred. This is set for companies and businesses as to their annual revenues to the year of activity that saw the occurrence of the event or fact. The said Decision also emphasizes the obligation to hold certified audit documents (such as notarized or dated contracts; the realization of profit or the execution/ actual delivery to the assignee) to be able to argue limitation periods and as a condition precedent to the acceptance of the request.