Evidentiary procedure must be conducted in order to examine the taxpayer’s deliberate participation in tax evasion

• 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

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