The article addresses the issue of the limitation period for tax liabilities secured by a compulsory mortgage. Particular attention is paid to the difficulties faced by taxpayers when applying for a certificate confirming the expiry of a tax liability due to the expiry of the limitation period. The article presents, among other things, interpretative disputes concerning the admissibility of examining the limitation period for liabilities in proceedings for the issuance of a certificate. The conclusion of the study is that the lack of clear and effective legal instruments leads to further violations of taxpayers’ constitutional rights, and that a real improvement in their situation requires systemic regulation of the effects of the Constitutional Tribunal’s judgments.