Intertemporal issues related to anti-tax avoidance clause on the example of the resolutions of the Council for Anti-Tax Avoidance of 18 December 2019

Abstract

The article discusses the line of the Council for the Prevention of Tax Avoidance in terms of intertemporal issues of the anti-tax avoidance clause and decisions of the creation moment of the tax benefit. The considerations refer to the Council resolutions No. 3/2019-5/2019 of 18 December 2019 and constitute the part of the first opinions of this institution regarding the application of the art. 119a of the Tax Ordinance Act.