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Tax disputes with the Slovak tax authorities

Tax disputes with the Slovak tax authorities in practice

A tax dispute in Slovakia does not begin in court. It begins with a letter from the tax office announcing a tax audit, then moves through the tax assessment, an appeal and an administrative action, and can end with a cassation complaint before the Supreme Administrative Court. Each stage has its own rules and its own deadline. Whatever is missed early on is hard to add later, because the courts mainly review what is already on file.

This page gives you an overview of the whole route, with links to each stage. As a law firm, we treat a tax dispute as a legal dispute: we analyse the file, draft submissions, appeals and court actions, and deal with the tax authority on your behalf. On accounting or transfer pricing questions we work alongside your tax adviser and accountant. If criminal proceedings open next to the tax case, we coordinate both.

What we help with

  • Representation during a tax audit
  • Submissions in the tax assessment proceedings
  • Appeals against decisions of the tax office
  • Administrative actions against decisions of the Slovak Financial Directorate
  • Cassation complaints to the Supreme Administrative Court
  • Disputes over VAT deduction
  • Coordination with the defence in tax-related criminal cases

Worth knowing

Appeal: 15 days

An appeal against a tax office decision must be lodged within 15 days of its delivery (Section 72 of the Slovak Tax Procedure Code). The appeal is decided by the Financial Directorate of the Slovak Republic.

Administrative action: 2 months

A decision of the Financial Directorate can be challenged in court within two months of its notification (Section 181 of the Slovak Administrative Court Procedure Code). The action is admissible only if an appeal was filed first.

Cassation complaint: 1 month

A judgment of an administrative court can be challenged by a cassation complaint within one month of delivery (Section 443 of the Administrative Court Procedure Code). It is decided by the Supreme Administrative Court, and representation by a lawyer is mandatory.

Tax and criminal proceedings

A tax audit and criminal proceedings can run at the same time. Under Article 47(1) of the Slovak Constitution, everyone may refuse to give a statement that would expose them or a close person to criminal prosecution.

Common questions

  • The earlier, the more options remain. There is most room during the tax audit and before a decision is issued, while evidence and submissions can still be added. We can also step in later, at the appeal or court stage.
  • An administrative action challenges a decision of the Financial Directorate and goes to an administrative court within two months. A cassation complaint challenges the administrative court's judgment and is decided by the Supreme Administrative Court. The deadline is one month and a lawyer is mandatory.
  • No. We are a law firm, and in tax matters we provide legal help in disputes. We do not prepare tax returns or keep accounts; on specialist questions we work with tax advisers and accountants.
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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.