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Time-limits for tax assessment
Červinková, Andrea ; Boháč, Radim (advisor) ; Kohajda, Michael (referee)
77 Abstract The purpose of my thesis is to analyze the current tax administration regulation with respect to the time-limits of tax assessment. The reason for my research is the fact that a new tax administration code came in force recently where lot of interpretational conclusions were codified. Due to the fact that the previously in force Act No. 337/1992 Coll., as subsequently amended, Code of Tax Procedure was prepared and approved in the hectic nineties of the last century, it has been suffering of several shortcomings. Some of its terms were not defined properly, some articles were not completely clear. Because this was an undesirable situation with a vast potential to negatively affect rights of its recipients, the code had to be completed and interpreted both by the Constitutional Court and the Supreme Administrative Court. These were the main reasons for the development of a completely new code instead of just another amendment. In the summer 2009 after long lasting discussions, the code was finally approved by the Czech legislation as the Act. No. 280/2009 Coll., Code of Tax Administration. The purpose of this paper is to determine how the main task was accomplished; this is whether the new code guarantees higher level of regulatory certainty for the tax administration recipients - above all for...
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Time-limits for tax assessment
Červinková, Andrea ; Boháč, Radim (advisor) ; Kohajda, Michael (referee)
77 Abstract The purpose of my thesis is to analyze the current tax administration regulation with respect to the time-limits of tax assessment. The reason for my research is the fact that a new tax administration code came in force recently where lot of interpretational conclusions were codified. Due to the fact that the previously in force Act No. 337/1992 Coll., as subsequently amended, Code of Tax Procedure was prepared and approved in the hectic nineties of the last century, it has been suffering of several shortcomings. Some of its terms were not defined properly, some articles were not completely clear. Because this was an undesirable situation with a vast potential to negatively affect rights of its recipients, the code had to be completed and interpreted both by the Constitutional Court and the Supreme Administrative Court. These were the main reasons for the development of a completely new code instead of just another amendment. In the summer 2009 after long lasting discussions, the code was finally approved by the Czech legislation as the Act. No. 280/2009 Coll., Code of Tax Administration. The purpose of this paper is to determine how the main task was accomplished; this is whether the new code guarantees higher level of regulatory certainty for the tax administration recipients - above all for...
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