Seminář: Klíčové trendy v judikatuře NSS (nejen) v daňové oblasti

I would like to invite tax advisors and their associates, lawyers, also judges, but also the general professional and business community to this special seminar.

At this seminar, I will share my findings regarding the main judicial lines NSS) useful for legal and tax advisory practice.

What I am particularly aiming for with this seminar:
- knowing jurisprudence means above all knowing the key decision-making lines of the NSS, including knowledge of corrections made or direct diversions
- in practice, it is often a matter of solving questions: which jurisprudence to use for your defense in a specific case and in a specific situation?
- in the defense against a specific "attack" by the FÚ, we often solve: How to contradict the jurisprudence used by the tax office? What jurisprudence weakens or directly contradicts the jurisprudence used by the tax office?
- some jurisprudence lines are already "ancient" and therefore relatively established, while others are much younger and therefore easier to contradict. Which ones are they in particular?
- a number of questions do not yet have a clear jurisprudential line - so there remains a relatively large chance of success
- a number of practical tax disputes often become disputes over the interpretation of jurisprudence - i.e. the links of jurisprudence it is good to know
- the history of decision-making by the National Court of Justice teaches us that significantly different decisions were gradually made on a number of topics - here this empirically confirms the opinion that jurisprudence can rarely be considered completely fixed and irreversible (especially in the case of a historically very short history of the entire existence of the current Supreme Administrative Court) - even in common-law countries, jurisprudence cannot be taken as an immutable dogma, much less here

It is an indisputable fact (whatever we think about it) that an important source law even in the environment of Czech (continental) legal culture is jurisprudence. Thus, knowledge and skills in working with jurisprudence are an essential part of the good work of a practitioner in the field of tax law.
During the more than 20 years of existence of the NSS, tens of thousands of judgments have accumulated. Logically, the question arises of how to work efficiently with such a large set. One of the ways is to look for key thematic lines and problems with the help of quantitative and qualitative research tools. This time, we will focus in more detail on one of the key competencies of a successful practitioner in the field of managing (or even preventing) a tax dispute, namely knowledge of the decision-making practice of the NSS, simply put, knowledge of jurisprudence. So we will delve into the depths of the Supreme Administrative Court's jurisprudence. We will find out which judgments are the most fundamental for practice and which trends and concepts are reflected in them. We will reveal the most frequently cited decisions and their impact on current and future practice. My goal is to provide listeners with a comprehensive overview of the key aspects that are necessary for any successful practitioner. We will go through specific cases and create an overview of the most important findings that will enable us to effectively navigate the world of tax law.

Designed not only for moderately or moderately advanced tax-law litigation professionals who will benefit from the specific experience and tricks of an experienced practitioner (from 30 years of experience) can certainly be useful, but also for experienced bards, who know very well that in law (and perhaps tax law in particular) "no one is a prophet", and therefore that any clarification or expansion of the instrumentality is not only possible, but also useful.

I looked for sources not only in my long-term litigation practice, but also with the help of the use of current IT technologies, including my own unique codes in the Python language and the use of artificial intelligence (especially ChatGPT).

Content of the seminar:
• An overview of the basic (current and historical) lines of argument in NSS decision-making (in the area of ​​tax law, but also in related topics)
• An overview of the most frequently cited decisions (over the entire period and in this decade) - what this means for our practice
• A more detailed analysis of approx. 50 jurisprudence forming the basis of the lines of argument that the NSS currently applies (in the last 3 years) />• Joint discussion: where, where and how to make it even better