Abstract

This article analyzes the difficulty of proving the substance of transactions for tax purposes. It points out that it is not enough to have tax receipts or accounting records, since these alone do not demonstrate that the transactions actually took place. It also warns that even conducting actual transactions is not sufficient if there is disorder in the documentation or accounting records. The article emphasizes the need to compile a complete file documenting the entire transaction process (from planning to completion), including contracts, quotes, and evidence of performance and delivery of goods or services. This enables the taxpayer to present solid evidence in the event of tax audits or litigation. Furthermore, it is noted that, in the event of disputes with the tax authority, the taxpayer may rely on presumptive, testimonial, and expert evidence, as well as on court rulings and principles such as good faith. The main challenge is to comprehensively demonstrate the economic reality of the transactions.