Publication details

Sporné momenty při posuzování běhu lhůty pro stanovení daně

Title in English Controversial moments in assessing the running of the tax assessment period
Authors

FELDEK Michael ROZEHNAL Tomáš

Year of publication 2022
Type Article in Periodical
Magazine / Source Portál Daně a účetnictví - expertní příspěvky
MU Faculty or unit

Faculty of Law

Citation
Web open access časopisu
Keywords running of the time limit; tax audit; tax return; time limit; objective time limit; rules for calculating time; preclusive time limit; request to file a supplementary tax return
Description The article deals with selected interpretative problems in calculating the time limit for tax assessment. The rules for the calculation of time represent an issue which the authors of the article consider to be one of the basic building blocks of the legal system, not excluding tax law. Their interpretation and application should therefore, in principle, be predictable and cause as little controversy as possible. In the authors' opinion, however, this is unfortunately not always the case. Therefore, in the article they deal with three problematic areas where they consider this problem to be the most pressing. The first is the applicability of the general rules for calculating the time for the assessment of tax. The second point of contention is the question of the applicability of non-retroactivity rules that may affect the length of the time limit. The last is the question of the possible extension and interruption of the period for the assessment of tax in connection with the request to submit a supplementary tax return and the subsequent control procedure of the tax authority.

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