Findings at a glance
- Traceability of the calculation
- Completeness of the data basis
- Requirements for counter-evidence
- Burden of proof and its reversal
3× exceeded · 1× met
Traceability of the calculationexceeded
The use of the procedure based on aids must be stated in the operative part of the decision.
CitationDaňový řád (280/2009 Sb.) § 98
What we provideEvery figure is traceable down to the individual document. The chain of calculation can be walked in both directions — from the result to the document and back.
Completeness of the data basisexceeded
Tax is determined by aids where it cannot be established by evidence — including without the cooperation of the taxpayer.
CitationDaňový řád § 98 Abs. 1
What we provideA full census across all accounts, suppliers and product groups. No sampling is used; 100 per cent is the upper limit and cannot be exceeded by any method.
Requirements for counter-evidenceexceeded
The authority must also take into account the circumstances from which advantages for the taxpayer arise — even where the taxpayer has not claimed them.
CitationDaňový řád § 98 Abs. 2
What we provideA closed system: purchasing, production, masses, unit counts, sales channel and revenue support one another. A single incorrect figure shows up against the others.
Further information — 1 axes
Burden of proof and its reversalmet
Determination by aids is subsidiary to determination by evidence.
CitationDaňový řád § 98 Abs. 1
What we provideThe evidence is prepared so that the reversal of the burden remains traceable and the counter-evidence engages with the calculation, not with the objection.