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Appealing a Slovak tax decision

Appealing a Slovak tax decision in practice

Every tax assessment decision comes with a note that you may appeal. The deadline is 15 days from delivery (Section 72 of the Slovak Tax Procedure Code), which is not long for a large file. The appeal matters for another reason too: without it, you cannot later bring an administrative action. Skip the appeal and you lose the chance to have a court review the decision.

Our work on an appeal starts with a review of the entire file. We look for where the tax office got the facts wrong, misapplied the law or breached procedural rules. From that we choose the core grounds, add evidence and set out what the appeal body should do. We write the appeal so that a later administrative action can build on it.

What we help with

  • Checking the deadline and how the decision was delivered
  • Reviewing the file and the grounds of appeal
  • Drafting and filing the appeal
  • Adding new evidence
  • Dealing with the appeal body
  • Preparing for an administrative action

Worth knowing

Deadline and where to file

The appeal is lodged within 15 days of delivery with the tax office that issued the decision (Section 72 of the Slovak Tax Procedure Code).

Who decides

If the tax office does not grant the appeal itself, it passes it to the appeal body. For decisions of tax offices, that is the Financial Directorate of the Slovak Republic.

Suspensive effect

An appeal filed in time has suspensive effect, so the decision is not enforced until the appeal is decided. The law provides for exceptions.

No appeal, no court action

An administrative action is admissible only if the ordinary remedies in the tax proceedings, meaning the appeal, have been used.

Common questions

  • It must identify the decision, state to what extent you challenge it, give the grounds and say what the appeal body should do. A general statement of disagreement is not enough; the grounds need to be explained.
  • It can uphold, change or annul the decision and send the case back. Its decision can be challenged by an administrative action within two months.
  • The Tax Procedure Code also has extraordinary remedies, for example reopening proceedings when new facts or evidence come to light (Section 75). Their conditions are stricter than for an appeal.
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This page is for general information, reflects Slovak law at the time of writing and is not a substitute for advice on your particular matter.