Review, Reopening of Proceedings, and Objection – Extraordinary Remedies in Czech Tax Law
Filed an appeal and lost? Or found out about a tax decision only after it became final? Czech tax law offers a few additional tools to challenge decisions—beyond the standard appeal. These are known as extraordinary or supervisory remedies, and they can sometimes reopen a closed case if specific legal conditions are met.
This article is part of the main guide to tax proceedings – see more here, where you’ll find a clear overview of each stage, practical tips and legal advice written in plain language.
Typical search queries include: “how to request tax decision review Czech Republic,” “reopening of tax case Czech law,” “objection to tax authority conduct,” or “what to do if I found out about the decision too late.” This article clearly outlines three extraordinary remedies, when they apply, and what they can achieve.
Review of a tax decision
Under Section 121 of the Czech Tax Code, a final decision may be reviewed ex officio—even without a request—if it’s found to be unlawful or contrary to public interest.
However, you can also initiate a review by pointing out serious legal errors. A higher tax authority will then examine the case and may:
uphold the decision,
modify it,
or cancel it entirely.
This is a rarely used and discretionary remedy, but it’s especially relevant when new court rulings cast doubt on the legality of the original decision.
Reopening of proceedings
Reopening is governed by Sections 122 and following of the Tax Code. It can be initiated:
ex officio, or
by request, if new facts or evidence emerge that couldn’t have been presented earlier.
A typical scenario: after the decision, you discover a document that fundamentally changes the outcome—such as proof of a payment or a mistake in your accounting software.
Strict deadlines apply: you must file the request within six months of discovering the new facts. Reopening is only granted in narrowly defined cases.
Objection to the conduct of the tax authority
This is not about challenging a decision but rather objecting to improper or unlawful behavior during the tax process. Under Section 261 of the Tax Code, you can file an objection if:
deadlines are being violated,
you are denied access to the case file,
the authority is biased or uncooperative,
your submissions are being ignored.
The objection is decided by a superior official or department head. It’s a fast-track way to address violations of your rights during ongoing proceedings—and often leads to a quick correction in the tax office’s conduct.
Lawyer’s recommendation
These remedies are powerful but strictly limited. If you’re considering a review or reopening, I strongly recommend a consultation—deadlines are short and chances of success depend on detailed legal evaluation. The most common mistake? Filing a request without evidence or after the deadline—and losing the final opportunity to challenge the case.
Want to challenge a final tax decision? Found new evidence or feel you weren’t given a fair chance? I’ll assess your situation, help draft a motion for review or reopening, and represent you in the process. Pricing from CZK 1,500 excl. VAT, always agreed in advance. Time is critical—these remedies are highly time-sensitive.
Contact a legal professional – I specialize in tax law.
Learn more here.
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- Naposledy aktualizováno: 17/07/2025
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Review, Reopening of Proceedings, and Objection – Extraordinary Remedies in Czech Tax Law
Print Filed an appeal and lost? Or found out about a tax decision only after it became final? Czech tax law offers a few additional