Daňová kontrola

Under Czech law

Tax audits are regulated by § 85–§ 88 of the Tax Procedure Code (daňový řád, Act No. 280/2009 Sb.). Since 2021 an audit formally begins with the delivery of a notice of initiation (§ 87), typically into the data box. The taxpayer must provide cooperation, but also holds rights: to submit evidence, to attend witness examinations and ask questions, and to receive the audit result (výsledek kontrolního zjištění) with a genuine chance to respond before the report is closed (§ 88) — the last practical moment to change the outcome.

The audit suspends the assessment limitation period; the basic three-year deadline of § 148 can stretch toward its ten-year maximum. Findings end in an additional payment assessment plus penalties (§ 251: 20 % of the increase) and late-payment interest (§ 252).

A practical example

A marketing s.r.o. faces an audit questioning deductibility of subcontractor invoices. The office suggests the services were never performed. The company''s lawyer and accountant assemble contemporaneous outputs — briefs, drafts, emails, meeting notes — and attend every witness hearing. Two of three years close without findings; the third ends in a modest assessment instead of a six-figure one plus VAT consequences.

When you need a lawyer

From the initiation notice, in any audit touching VAT chains, subcontractors, or transfer pricing. Evidence not marshalled during the audit rarely wins later at the appeal stage or the administrative court — the file is built now.