Tax Administrator

Tax 

The Supreme Administrative Court resolved the matter of a time limit for tax assessment that started before 2011

In a long-awaited judgment, the Grand Chamber of the Supreme Administrative Court (the “SAC”) resolved the matter how to correctly calculate the prescription time limit in situations where the time limit for ta… 

Tax 

The Regional Court ruled on the issue of the beneficial owner of royalties

We bring you a recent judgment of the Regional Court in Brno (no. 29 Af 62/2018), which considered the issue of the beneficial owner of income arising from the royalties paid abroad. Recently, beneficial owners… 

Tax 

Concept of abuse of law in focus of tax administration again

The current case-law shows that the concept of the abuse of law is becoming the inseparable part of tax practice over time; therefore, we bring you another judicial decision on this topic, this time it was made… 

Tax 

Use of camera recordings of the Police of the Czech Republic in tax proceeding

Last year, we informed you of a judgment in which the Supreme Administrative Court upheld the legality of the use of evidence of the movement of a motor vehicle recorded by the Police that the Tax Administrator… 

Tax 

Criminal judgment as evidence in tax proceedings

In a recent judgment in Case No. 6 Afs 125/2021, the Supreme Administrative Court (“SAC”) dealt with the question of when the tax administrator is bound by a criminal court judgment and when it is not bound by … 

Tax 

Interest on a loan and the prohibition of abuse of law in the judgment of a Regional Court

Following the letter of the law may not always be sufficient to defend the tax regime applied. Increasingly, the tax authorities are applying the principle of the prohibition of abuse of law, the primary premis… 

Tax 

When can a taxpayer be entitled to “interest on interest”?

In practice, we have recently noticed an increase in claims for the second (or third, etc.) interest in relation to the late repayment of overpayments of first interest from the tax administrator, often referre… 

Tax 

When is a document presumed to have been delivered to the taxable entity’s data box?

As part of the shutdown of data boxes at the end of 2022, the data box system was updated so that the generated proofs of delivery of documents delivered by administrative authorities are in accordance with las… 

Tax 

Expanding the scope of information that the Tax Administrator may obtain about taxpayers

Today, it is hardly surprising that the Tax Administrator can obtain a large amount of information about taxpayers for the purposes of tax administration. This is made possible by the relatively extensive oblig…