What is a tax security order?

A tax security order (zajišťovací příkaz) is an administrative decision that temporarily freezes your assets to secure a potential future tax liability. The tax authority does not need a final assessment—they just suspect that you may not be able (or willing) to pay in the future.

Such an order can be issued without prior notice. The tax office often argues that if the taxpayer were informed in advance, they could hide or transfer assets. In reality, this means the first you hear about it is when your business comes to a halt.

What can be frozen?

– Funds in your bank accounts
– Movable or immovable property
– Receivables owed to you by clients
– Even assets held by third parties, if linked to your company

In effect, the entire business can be paralyzed—and often before any final tax assessment is even issued.

What is a preliminary measure?

A preliminary measure (předběžné opatření) is a temporary order meant to secure the purpose of the tax procedure or prevent its frustration. It may prohibit the taxpayer from disposing of assets or require them to take specific actions.

Preliminary measures are less common than security orders but potentially even harder to predict. The authority can issue them at any point during tax proceedings, without a final decision being in place.

How can you defend yourself?

A tax security order can be appealed within 30 days from its delivery. The appeal should be well-prepared and submitted promptly—because success often depends on pointing out procedural flaws or disproportionality.

Preliminary measures can also be challenged, but sometimes only through court proceedings, especially when they affect fundamental rights or cripple business operations.

Risks and consequences

The tax authority can issue a security order based only on estimates or suspicion. If you wait too long, you may lose your chance to appeal. In many cases, it takes months to lift the freeze, which can be financially devastating.

From experience, early legal intervention makes a major difference. Many orders have been overturned thanks to prompt appeals that exposed errors in the reasoning or procedural missteps. Even when the measure is not canceled entirely, lawyers can often negotiate partial unfreezing or alternative solutions.

Lawyer’s recommendation

I’ve helped clients whose entire business accounts were frozen overnight—without warning. Some were pushed to the edge of collapse. If this happens to you, do not assume it will go away. Legal action must be immediate. Even when the situation seems hopeless, there are ways to push back. Fast reaction is critical.