Informal communication with the tax administrator
Does the tax administrator write you emails? Do they call you? Although the Tax Procedure Code only regulates formal methods of communication (data box, letter mail, etc.), emails and…
Regional Court opposed to tax administrator’s approach to R&D allowance
The Regional Court of Justice in Hradec Králové in judgment No. 52 Af 18/2016 dealt with a case where a tax administrator challenged a research and development (R&D) allowance claimed by…
Tax administrator must not assess evidence put forward with bias
If a taxpayer produces evidence in tax proceedings, a tax administrator must assess such evidence both separately and in combination. If they have doubts about the evidence, they may…
Services received – how to prove their tax deductibility?
Do you receive services from intracompany or external providers whose actual substance is uncertain or whose benefit for your company is doubtful? The tax authority may no longer regard the mere provision of such a service’s tax document as…
Witness testimonies in tax proceedings?
Along with supporting documentation, witness testimonies are the most common and most important means of proof. A tax administrator’s refusal to hear a witness may even lead to the…
SAC sets limits to fighting VAT fraud
Where a supply has been affected by VAT fraud, the tax administration demands almost investigative checks of suppliers to maintain the entitlement for VAT deduction; and this may happen at any point in the chain. The Supreme Administrative Court …
Interest on interest according to SAC? Yes, sometimes
The Supreme Administrative Court (SAC) has recently dealt twice with the possibility of awarding a taxpayer interest on the interest that the tax administrator refused to award and pay…
Better times ahead for cross-border trading taxpayers?
The Supreme Administrative Court has recently stood up for a taxpayer who effected a supply of goods to another member state, i.e. a transaction exempt from VAT with entitlement to deduction. The crucial point of the dispute was the taxpayer’s good…