New tools for the recovery of arrears
Starting this year, the tax authorities are not limited by local jurisdiction when recovering tax arrears. At the same time, from 1 July 2025, the customs administration can use a new power in the event of an u…
The Supreme Administrative Court: Holding structure is not abuse of law
What is a holding company and what activities should it perform? This question was examined by the Supreme Administrative Court (SAC) in a new judgement, where it assessed whether the establishment of a holding…
Transfer Pricing: Supreme Administrative Court’s judgment on the use of the cost plus method
The Supreme Administrative Court (‘SAC’) issued judgement No. 6 Afs 225/2023-58, which addresses the issue of transfer pricing and confirms the application of the cost plus method (‘Cost+’) in the case of intra…
When to claim a default interest waiver
Waiver of default interest and interest on the amount deferred is an important instrument that helps taxpayers to reduce the financial impact of additional tax assessments or other situations. The tax authority…
The SAC resolved a long-lasting uncertainty regarding the interest on withheld tax deductions
In its recent judgment, the Supreme Administrative Court (SAC) took up its preceding ground-breaking decisions regarding the tax deduction interest rate and responded to the probably last remaining question abo…
Use of the police’s CCTV footage in tax proceedings before the SAC for the second time
After the intervention of the Constitutional Court, a case concerning the possibility of using the police’s CCTV footage in tax proceedings has returned to the Supreme Administrative Court (the "SAC"). We infor…
Courts confirm possibility of retroactive application of investment incentive
Last autumn, the courts dealt with an issue that had troubled many tax payers. Is it possible to claim a tax relief arising from investment incentives during the additional assessment procedure? The courts have…
SAC: A request for international exchange of information can materially initiate a tax audit
One of the most important judgments of 2023 was the judgment in case No. 6 Afs 59/2023, by which the Supreme Administrative Court (“the SAC”) upheld the taxpayer’s cassation complaint concerning the tax adminis…
Methodological information on taxation of benefits from 1 January 2024
To improve legal clarity, the General Financial Directorate has finally released methodological information regarding the taxation of benefits and other perks offered by employers to employees starting on 1 Jan…