Findings at a glance
- Traceability of the calculation
- Completeness of the data basis
- Requirements for counter-evidence
- Burden of proof and its reversal
4× exceeded
Traceability of the calculationexceeded
A LIST OF THE AIDS on the basis of which the tax was determined must be attached to the protocol on determination of tax by aids.
CitationDaňový poriadok (563/2009 Z. z.), § 49 ods. 1
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
The aids include documents, tax returns, extracts from public registers, THE TAX FILES OF OTHER TAXPAYERS, expert opinions, testimony, bank account statements and the administrator’s own knowledge of similar taxpayers.
CitationDaňový poriadok, § 48 ods. 3
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 taxpayer may make written representations ONLY on compliance with the statutory conditions for this method and on the consideration of advantages in their favour — within 15 working days.
CitationDaňový poriadok, § 49 ods. 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 reversalexceeded
When determining tax by aids the authority is obliged also to take into account the circumstances established from which advantages for the taxpayer arise — even where the taxpayer has not claimed them.
CitationDaňový poriadok, § 48 ods. 5
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.