Skrytá daňová kontrola

Abstract

This diploma thesis deals with the issue of hidden tax control as a specific phenomenon of procedural tax law. The aim of the thesis is to provide a comprehensive and substantively oriented definition of this concept, with an emphasis on distinguishing criteria, in particular the nature and intensity of the tax authority’s actions, the scope of requested information, the time factor and procedural guarantees, as well as their impact on the time limits for tax assessment. A secondary aim is to refine the boundary between information-gathering activities and control procedures. The theoretical part describes the fundamentals of tax administration and the procedures of the tax authority. The practical part is based on an analysis of the case law of administrative courts, on the basis of which general criteria for assessing hidden tax control are defined. The result of the thesis is their systematization, an evaluation of current practice, including recommendations for individual actors, and proposals for further development.