This article aims to present and assess the views of the administrative court doctrine concerning the tax consequences of a share exchange transaction based on personal income tax in the case where a limited liability company under organisation is involved in the exchange. This issue is the subject of numerous judgments with two competing lines of jurisprudence. Primarily, administrative courts differently interpret the legal status of a limited liability company under organisation. Some courts argue that this company may be involved in a share exchange transaction as both a limited liability company under organisation and a limited liability company constitute the same legal entity which is in different constitutional stages (phases), whereas others claim that a limited liability company under organisation is a legal entity with an independent legal capacity, separate from a limited liability company. This means that in certain cases a natural person who is a personal income taxpayer may take advantage of the exemption from the exchange of shares as referred to in Article 24(8a) of the Personal Income Tax Act in a situation where a limited liability company under organisation is involved in the exchange of shares, while in other cases the transaction is not tax neutral for them.

The objective of this article is to present and evaluate the views of the judicial-administrative judicature on the possibility of applying to additional fees for parking in the paid parking zone the provisions of Chapter III of the Tax Ordinance, in particular those relating to the interruption of the limitation period. This issue is the subject of numerous rulings, in which two competing lines of jurisprudence can be found.