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FP-FpdpPAcad. year: 2026/2027
Upon completion of the course, students should possess a broader understanding of the practical aspects of selected areas of tax proceedings. They should also have the opportunity to put into practice their argumentation skills, oral presentation abilities, analytical thinking, and capacity to address issues within a broader context, as well as to prepare specific documents based on given assignments. Please refer to the syllabus below for details regarding the requirements for individual topics and the assessment of outputs.
Language of instruction
Number of ECTS credits
Assignment to study programme types
Mode of study
Guarantor
Department
Entry knowledge
Basic knowledge of tax law.
Rules for evaluation and completion of the course
Assessment of practical assignments based on their nature (oral or written outputs), enabling students to "step into the shoes" of the various parties involved in tax proceedings and receive feedback from officials of the Appellate Tax Authority.
Credit is conditional upon mandatory attendance at seminars and the completion of assigned tasks to a satisfactory standard.
Aims
This course serves as a practical introduction to the fundamental aspects of tax procedure regulations, with a particular focus on their application to income tax and value-added tax. Students will develop their knowledge through both a theoretical foundation - provided in the introductory segment of each seminar via a lecture-style explanation of key legal contexts - and, more importantly, through the acquisition of practical skills gained via group work based on specific assignments and supervised by the instructors.
Emphasis will be placed on explaining critical concepts using examples drawn from the professional experience of staff at the Appellate Financial Directorate (AFD), examining issues from the perspectives of both tax authorities and - to some extent - taxpayers and their representatives. Over the course of six seminars, students will be guided through the entire tax audit process: from the initial assessment of documents submitted by the taxpayer and the shifting of the burden of proof between the tax authority and the taxpayer, through the taxpayer’s response to the authority’s concerns, to the evaluation of specific evidence and the formulation of conclusions based on the audit. When preparing arguments for proceedings before the tax authority, student groups will have the opportunity to consult with assigned OFŘ staff members at the Directorate’s offices; these consultants will assist in outlining the groups' approaches to ensure the case follows a logical structure. However, AFD representatives will not devise the solutions for the groups; their role is strictly consultative, in keeping with the educational objectives of the clinical course.
The aim of the course is thus primarily to develop practical skills in the field of tax law. Upon completion of the subject, students should possess a broader understanding of the practical aspects of selected areas of tax proceedings; they should have the opportunity to put into practice their argumentation skills, oral presentation abilities, and capacity for analytical thinking and problem-solving within a broader context, as well as gain experience in preparing specific documents based on given assignments.
Study aids
Prerequisites and corequisites
Basic literature
Recommended reading
Elearning
Classification of course in study plans
Exercise
Teacher / Lecturer
Syllabus
1. Tax audit – verification of the taxpayer's assertions and the fulfillment of their initial burden of proof by the tax administrator. In the first part of the seminar, students will receive an introduction to the legal framework governing tax audits and the shifting of the burden of proof between the tax administrator and the taxpayer. Students will then be divided into groups of no more than five. All groups will represent the tax administrator. They will work on a case involving a simultaneous income tax and VAT audit of a taxpayer. Based on the submitted tax return and selected documents, they will identify potentially suspicious items and focus their further efforts on them.
2. Evidentiary proceedings – meeting the taxpayer's burden of proof. At the start of the seminar, students will be introduced to the evidentiary process within tax proceedings. Students will remain in the same groups. During the seminar, they will represent the taxpayer (or the taxpayer's representative). Each group's task will be to prepare a response to a formal request for evidence. For this purpose, they will use the requests for evidence drafted by the groups as an output from the previous seminar. The students' goal will be to prepare a response that maximizes their chances of successfully discharging the burden of proof.
3. Witness testimony and evaluation of evidence. The seminar will begin with an explanation of witness testimony in tax proceedings and the principles governing how the tax administrator conducts the taking of such testimony. Subsequently, students will be introduced to the process of evaluating evidence. Students will again be divided into the same groups, representing both the tax authority and the taxpayer (or their representative). A simulated witness examination will then take place. Groups will have the opportunity to prepare for the examination in advance by formulating questions and an examination strategy. Employees of the Regional Tax Office will act as witnesses. Following the examinations, the groups will evaluate the witness testimonies. They will place their evaluations in the context of other evidence available to them from previous seminars.
4. Evaluation of the evidence gathered – income tax. The seminar will begin with a discussion of the substantive legal issues of the case. Students will work in the same groups as before. All groups will represent the tax authority. Their goal will be to summarize the results of the evidentiary proceedings and reach a conclusion regarding the findings with which they, as the tax authority, would close the income tax audit. Final conclusions must be submitted no later than one week after the seminar ends.
5. Evaluation of the evidence gathered – VAT. The seminar will begin with a discussion of the substantive legal issues of the case. Students will work in the same groups as before. All groups will represent the tax authority. Their goal will be to summarize the results of the evidentiary proceedings and reach a conclusion regarding the findings with which they, as the tax authority, would close the VAT audit. Final conclusions must be submitted no later than one week after the seminar ends.
6. Proceedings before the appellate body. The final seminar will feature a simulated appeal proceeding, with students divided into the same groups as before. The groups will successively present the conclusions they reached regarding specific taxes during the tax audit.
Self-study
Individual preparation for an ending of the course