Tax Code Amendment and VAT Rulings: Verification Reforms, Triangulation and Export Cases

The government published draft Tax Code amendments expanding verification powers and admissible evidence, imposing a 3-month deadline for verifications, requiring taxpayers to be informed of the process and outcome, adding protections where no irregularities are found or where the taxpayer follows the authority’s findings, and introducing new voluntary security options, broader reduced-interest use, a duty to rely first on data already held, waiver of appeal rights, a 14-to-30-day appeal deadline extension, merits-based review of security decisions, and the possibility of a tax clearance certificate in restructuring; adoption is planned for Q1 2027.
The General Court held that invoices issued years after the supplies, adding “reverse charge” only later, do not retroactively qualify the transactions for triangulation simplification under the VAT Directive, so related VAT corrections cannot be made in current or future periods.
The Supreme Administrative Court confirmed that temporary vacancy does not break the business-use link for real estate held solely for letting/management, so such properties remain subject to the highest property tax rates.
In export cases, the Supreme Administrative Court reaffirmed that the 0% VAT rate depends on actual export outside the EU, not just formal customs documentation; the evidentiary list is open, and other reliable proof can suffice if there is no fraud or abuse.

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.