The subject of this article is an analysis of the judgment of the Court of Justice of the European Union in case C-235/21. The judgment states that, in certain situations, a contractual agreement concluded between two parties may be considered to be an invoice within the meaning of Art. 203 of Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax. The author attempts to identify the specific requirements that a contractual agreement must meet in order to be recognized as an invoice. In the light of the analysis carried out, such a contractual agreement can be recognized as an invoice if it clearly indicates that the taxable transaction has been carried out. This criterion can only be met by a contract relating to the transfer of ownership of the goods. It must also show that both parties are taxable persons acting as such, and it must specify the amount of tax and the tax rate. The latter may be derived indirectly. Finally, even if the contract meets the abovementioned conditions, it will not be considered an invoice if the supplier of the goods issues an invoice after the conclusion of the contract. Keywords: VAT, invoice, contract

In this article, the authors analyse the concept of the tax liability of persons deducting income tax payments on account. The authors noted that the paying agent performs his own obligation to collect, or withhold, an amount of money from a person who is not a taxable person and to transfer that amount to the relevant tax authority. This obligation arises as a result of the occurrence of an event described in a statutory provision that imposes an obligation on the paying agent. Under the Tax Ordinance Act the paying agent is liable for his failure to withhold a tax payment or to transfer the tax withheld to the relevant tax authority, but in the opinion of the authors' the applicability of this provision to the paying agent deducting income tax payments on account after a fiscal year end is limited. The authors present the view that adjudicating on the tax liability of paying agents deducting income tax payments on account after a fiscal year end is possible only in the event that the amount paid by the taxpayer is lower than the amount of the tax due, and this understatement results from the fact that the paying agent does not take steps to collect the payments on account and transfer them to the account of the tax authority.