- The Supreme Administrative Court has ruled that tax authorities cannot secure any additional tax liability on a taxpayer’s assets, including the additional tax liability referred to in Art. 112c of the VAT Act.
- This decision was made in response to the increasing practice of tax authorities securing potential tax liabilities before issuing the final tax decision.
- The court found that there was no need to take into account the principle of proportionality or conduct evidentiary proceedings aimed at investigating the taxpayer’s conscious participation in tax fraud.
- The decision has been welcomed by experts.
Source MDDP