An amendment to Czech tax law includes a provision that the statute of limitations for making a tax assessment does not run while there is a pending international request for tax information. This pause on the limitations period for assessment does not apply if the tax at issue is value added tax (VAT).
The Supreme Administrative Court recently issued a judgment concluding that with respect to income tax, the time limit for assessing tax does not run during periods when there are any pending international requests for information (regardless of when the limitation period on assessment started to run).
International requests for tax information, thus, have implications for the limitation period for assessing tax. Specifically, such international requests for information may take months (or even years). Thus, any pending tax inspections may be extended during this period of time, instead of the assessment being limited by the standard three-year time limit provided for assessing tax. If the inspection then results in an assessment of additional tax, the resulting late-payment interest will be based on the longer period including the information request.
Read a November 2019 report prepared by the KPMG member firm in the Czech Republic
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