Every statutory claim in the article, with the provision and the primary source. Statutes read on 22 August 2026. Every link below was checked and returned a working page on 14 September 2026; the one exception is recorded in the gaps section, and it is the one the article already discloses.
Where a finding is marked not found, that means I did not find a rule, not that I proved there isn't one. Where it is marked reported, I saw the text somewhere other than the official publisher and say so.
Spain
| Claim in the article | Provision | Source |
|---|---|---|
| Whoever takes over an economic activity is liable for the tax the previous owner ran up in it, including amounts withheld from staff | Ley 58/2003 General Tributaria, art. 42.1.c | BOE consolidated text · article text |
| The liability is joint and several, so the agency need not chase the seller into bankruptcy first | Same article, read against art. 41.2; confirmed by a tax tribunal ruling | TEAR Valencia, resolución 46/02887/2019 |
| Doesn't apply to buyers of isolated items unless they let the activity continue; doesn't apply to purchases out of an insolvency | Art. 42.1.c, second and fourth paragraphs | article text |
| The buyer may ask for a detailed certificate with the seller's agreement; liability is then limited to what it lists; silence for three months exempts; a request after completion has no effect; not asking adds his penalties | Art. 175.2 LGT | article text · BOE |
| The tax agency runs it as a named procedure | AEAT procedure RA17, certificado de sucesión de actividad | AEAT procedure page |
| Implementing regulation for the certificate | Real Decreto 939/2005, art. 125 | BOE |
| The assessment window is four years and restarts on any formal notice to the taxpayer | Arts. 66 and 68.1 LGT | art. 66 |
| The certificate covers only what the issuing office assesses, and that office collects national tax | AEAT's own scope statement on the procedure page, read against the competence structure in art. 5 LGT | AEAT procedure page |
| Staff transfer with the business along with social security obligations, and for three years buyer and seller are jointly liable for unpaid pre-transfer wages and contributions, including for people never on the payroll | Estatuto de los Trabajadores, art. 44 and 44.3 | BOE consolidated text |
| Dismissal costs run to about 33 days' pay per year of service, capped at two years, with older service and economic dismissals calculated differently | Estatuto de los Trabajadores, arts. 53 and 56 | BOE consolidated text |
Belgium
| Claim in the article | Provision | Source |
|---|---|---|
| The sale is not effective against the treasury until the end of the month following the month the collector is notified; after that the buyer is liable alongside the seller for tax and non-tax debts, capped by what he had paid or credited | Law of 13 April 2019 establishing the recovery code, art. 50 §1–§2 | reported, official gazette mirror |
| The rule used to be art. 442bis of the income tax code and moved in 2019, in force from 1 January 2020 | Same law; commencement stated by the finance ministry | FOD Financiën, recovery section |
| Only the seller can apply for the certificate; it must be refused if anything is owing or if an audit has been announced or is running; it has to be dated within the 30 days before the deal is notified | Art. 50 §3 of the same code | reported, mirror · practice confirmed on SPF Finances, certificate page |
| A separate statute does the same for social security contributions, with its own certificate from a different body | Law of 27 June 1969, art. 41quinquies | reported, mirror · practice confirmed on socialsecurity.be, employer attestations |
Luxembourg
| Claim in the article | Provision | Source |
|---|---|---|
| The buyer is liable alongside the former owner, but only where the business changes hands as a whole; the tail runs to the last full tax year before the sale plus the part-year up to it; purchases out of a bankruptcy estate are excluded | Loi générale des impôts of 22 May 1931 (Abgabenordnung), § 116 | Legilux |
| A buyer who finds the seller's returns were wrong, incomplete or never filed must tell the tax office within a month, or become personally liable | Same law, § 117 | Legilux |
| § 116 contains no certificate mechanism; the general certificate the tax administration issues is described as confirming a taxpayer's own position | Reading of § 116; ACD's own description | ACD FAQ for companies |
Poland
| Claim in the article | Provision | Source |
|---|---|---|
| The buyer of an enterprise or an organised part of one is liable with everything he owns, jointly with the seller, for arrears up to the day of purchase, capped at the value of what he bought; purchases in enforcement or bankruptcy are excluded | Ordynacja podatkowa, art. 112 and 112a | Dz.U. 2026 poz. 622 |
| No decision can be issued more than five years after the end of the year the arrears arose, with three more years to collect | Same act, art. 118 §1–§2 | Dz.U. 2026 poz. 622 |
| The certificate of the seller's arrears: issued freely to the seller, to the buyer only with the seller's consent, within seven days; the buyer is not liable for arrears it doesn't show; liability returns for anything arising if more than 30 days pass between issue and sale | Same act, art. 306g and art. 112 §6–§7 | Dz.U. 2026 poz. 622 |
| The fee is 21 złoty | Ustawa o opłacie skarbowej, schedule | Dz.U. 2025 poz. 1154 |
| The civil code makes the buyer jointly liable for the enterprise's trade debts, capped at its value, unless he did not know of them despite exercising due care; this cannot be excluded by contract without the creditor's agreement | Kodeks cywilny, art. 55⁴ | Dz.U. 2026 poz. 795 |
| The social insurance law borrows the tax rules for contribution arrears by naming which articles apply; it names art. 112 §1–5 and does not name §6–7 or the certificate provision | Ustawa o systemie ubezpieczeń społecznych, art. 31 and 32 | Dz.U. 2026 poz. 199 |
Netherlands
| Claim in the article | Provision | Source |
|---|---|---|
| Chapter VI is a closed list of roughly 25 grounds for making a third party liable for someone else's tax, and "buyer of a business" is not among them | Invorderingswet 1990, arts. 32–49 | wetten.overheid.nl |
| Articles 34 and 35 can make you liable for someone else's payroll tax where the business hires through an agency or works down a subcontracting chain | Same act, arts. 34 and 35 | wetten.overheid.nl |
| A transfer of a whole set of assets counts as no supply for VAT, and the acquirer steps into the transferor's position | Wet op de omzetbelasting 1968, art. 37d | wetten.overheid.nl |
| Staff transfer by law, and the seller stays jointly liable for a year afterwards for obligations arising before the transfer | Burgerlijk Wetboek, Boek 7, art. 663 | wetten.overheid.nl |
Ireland
| Claim in the article | Provision | Source |
|---|---|---|
| A transfer of business is deemed not to be a supply for VAT, and no general successor rule for the seller's tax debts was found | Value-Added Tax Consolidation Act 2010, s. 20(2)(c) | revised acts · Revenue manual, Transfer of Business |
| Where the deal includes a capital good, the buyer becomes successor to the previous owner's obligations on it | Same act, s. 64(10)(c)(ii) | revised acts |
| Staff transfer, except where the seller is in insolvency proceedings, and that carve-out falls away if the insolvency was arranged to get round the rules | S.I. No. 131/2003, reg. 4(1) and reg. 6(1) | Irish Statute Book |
United Kingdom
| Claim in the article | Provision | Source |
|---|---|---|
| Liabilities move from seller to buyer only if both apply for it | Value Added Tax Act 1994, s. 49(3) | legislation.gov.uk |
| Taking over the seller's VAT registration number makes his outstanding VAT on that number yours, including VAT on stock and assets he kept | VAT Regulations 1995, reg. 6(1) and 6(3)(a); form VAT68 | regulation · HMRC VAT Notice 700/9 |
| Capital Goods Scheme obligations transfer on property of £250,000 or more | VAT Notice 700/9, §3.1 | HMRC |
| The tax authority can make you jointly liable for the tax of a company that replaced insolvent ones: at least two insolvencies inside five years, debt over £10,000 and more than half the unsecured liabilities, same or similar trade, and a relevant connection to the new company | Finance Act 2020, Schedule 13, para. 3 | legislation.gov.uk |
| Staff transfer, and any act or omission of the seller before the transfer counts as the buyer's | TUPE 2006, reg. 4(1)–(2) | legislation.gov.uk |
| Unpaid PAYE does not transfer: the new employer is not liable for tax deductible before the change | Income Tax (PAYE) Regulations 2003, reg. 102(4) and 102(6) | legislation.gov.uk |
| Unpaid National Insurance does not transfer: the succession rule defines "employer" as the employer before the change | Social Security (Contributions) Regulations 2001, reg. 72 | legislation.gov.uk |
The gaps, stated plainly
These are in the article too. They are repeated here so the list is not more confident than the piece it supports.
Belgium's official gazette was unreachable. `ejustice.just.fgov.be` returned server errors on every attempt on 22 August 2026, and was still not answering when these links were rechecked on 14 September 2026. The Belgian statutory text therefore comes from a mirror that publishes the official Monitor, with the substance confirmed on the finance ministry's own pages. Treat the wording as reported rather than verified against the publisher.
Belgium's employment provisions are not cited in the article. The text of CAO 32bis arts. 7–8 was available only as a scan without a text layer, and what I have came from machine recognition. It has not been checked by eye, so it was kept out of the article rather than used with a hedge.
Luxembourg is half-answered. Liability under § 116 is confirmed. Whether any other instrument performs the job of a certificate, I could not establish. The position on social security contributions and on staff I did not confirm at all. And § 117 does not tell me, from the section I read, whether the month runs from the purchase or from the discovery.
Ireland's employer social insurance arrears. I found no successor rule, but I also did not find a provision saying there isn't one, which is a weaker finding than the Dutch closed list.
Poland's contribution gap is read from the statutes, not from the courts. The lists in arts. 31 and 32 are primary text and I read them. I have not checked how the courts read the omission of §6–7.
Spain's employment figures sit outside this pass. The three-year joint liability and the dismissal scales come from the employment code, not from the tax statutes this article is built on.
Portugal, Italy and France are absent because I could not confirm their rules against primary law in this pass, and I will not cite an article number I have not read.
The United States was not read at all. There is no national register and successor liability is a state-level question with clearance certificates of its own. Treat it as unchecked rather than clear.
Compiled by Grig Kochedykov, Provenance Diligence. Corrections welcome and published the same day: this would not be the first time. The dataset behind an earlier piece described a method it had not used; that was corrected in public, and no measured value changed.