Fiscal subject related
Before starting a tax inspection, the tax authority must inform the taxpayer in writing by sending a tax inspection notice.
The notice must be sent before the inspection begins, within the following deadlines:
- 30 days in advance for large taxpayers,
- 15 days in advance for all other taxpayers.
Only after this notice period can the actual inspection start.
During a tax inspection, the taxpayer has the following rights:
- To be officially notified about the inspection.
- To be inspected only for taxes and periods that are still within the legal limitation period.
- The general limitation period is 5 years, unless the law states otherwise,
- It starts on July 1 of the year following the year in which the tax became due.
- To request a postponement of the inspection start date once.
- To be inspected only once per tax type and per period.
- To request identification (legitimation) of tax inspectors.
- To be protected by tax secrecy rules.
- To receive written confirmation if inspectors retain any documents.
- To be informed of the inspection results.
- To challenge the tax decision issued after the inspection.
- To have business activity disrupted as little as possible.
- To receive clear and complete information during the inspection.
- To be the first party asked to provide explanations or information.
- To refuse to provide information, within legal limits.
- To benefit from specialized assistance (e.g. accountant or tax advisor).
During the inspection, the taxpayer must meet the following obligations:
- Allow inspectors access to business premises,
- Provide adequate working space and logistics for inspectors,
- Submit all accounting and tax documents needed to calculate taxes,
- Cooperate with the tax inspection body,
- Properly manage, store, and archive accounting and tax records, keeping them at the tax domicile or secondary offices,
- Provide requested information to inspectors,
- Appear at the tax authority’s offices, if requested,
- Comply with measures ordered by the tax inspection body,
- Pay any additional taxes, fees, or social contributions, as well as interest and late-payment penalties, established during the inspection.
The duration of a tax inspection depends on the taxpayer’s size and structure and cannot exceed:
- 180 days – large taxpayers and taxpayers with secondary offices,
- 90 days – medium-sized taxpayers,
- 45 days – other taxpayers.
If the inspection is not completed within double these time limits, it automatically ends without:
- a tax inspection report, or
- a tax decision (or decision not to amend the tax base).
The tax authority may resume the inspection only once, for the same taxes and periods, and only with approval from a higher-level authority.
To handle a tax inspection more easily:
- Keep accounting and tax records well organized and up to date.
- Ensure every transaction can be clearly justified.
- Cooperate openly with inspectors and respond on time.
- Consider working with an accountant or tax consultant during the inspection.
- Maintain professional and respectful communication with the tax authorities to avoid misunderstandings.
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