It is generally accepted that the tax administrations must complete the tax audits within a reasonable time. Such time limitations for audit activities are related to proportionality and certainty principles. Time requirements may be regulated within the domestic law which is the case in Turkey. However, countries may not implement time limitations at all or even if they do, they may not apply the provisions effectively. In that case the legal protection of the taxpayers from lengthy audits is worth discussing. The author in this article discusses the taxpayer’s situation from the perspective of fair trial rights.