Czech Republic: Taxpayer must prove temporal connection between claimed expenses and relevant tax period (Supreme Administrative Court decisions)
Taxpayer bears burden of proof.
The Supreme Administrative Court recently issued decisions in three cases (21 Afs 107/2025, 8 Afs 253/2024, and 4 Afs 214/2024-87) underscoring the importance of establishing a clear substantive and temporal connection between claimed expenses and the relevant tax period.
The court emphasized that the taxpayer bears the burden of proof for establishing that the underlying supplies were actually provided, as well as for showing a clear temporal and substantive connection with a specific tax period.
Read a March 2026 report prepared by the KPMG member firm in the Czech Republic