Nový pokyn MF o stanovení lhůt při správě daní

A new internal directive from the Ministry of Finance, MF-20, regarding the setting of deadlines in tax administration has recently been published, replacing the previous directive MF-5. The new rules came into effect on January 1, 2026.

The new directive does not bring revolutionary changes. Instead, it primarily updates and clarifies the existing rules.

From a practical perspective, the most significant change is the extension of the deadline for issuing binding assessments on transfer pricing (§ 38nc of the Income Taxes Act) from three to six months.

Other changes are mostly technical in nature. These include, for example:

• Adjustments to the rules for pausing the running of deadlines (e.g., for selected electronic submissions).
• Changes to the moment from which the deadline resumes running after a decision is annulled by a court (upon delivery of the court decision to the tax authorities).
• The cancellation of the automatic extension of the deadline when submission is made to a tax office that is not locally competent.

The directive applies to both proceedings initiated from the date of its effectiveness and to ongoing proceedings that were initiated before this date. The time elapsed before the directive's effectiveness is also included in the calculation of deadlines.

Author:

Jakub Tměj

Petr Sedláček