By Chrysostomos Tsoufis

The change of time is getting closer and closer and apart from the Christmas songs, the bells have started ringing for those who have open cases with the tax office which expire on December 31.

Following relevant orders from Giorgos Pitsilis, her services AADE they work day and night so that the “ravasaki” reach their recipients on time, who in the past hid income.

Priority is given to pending cases concerning:

– Undeclared income from wages and pensions
– Non-return of VAT
-Concealment of income from real estate and self-employment
– Late submission of customer-supplier consolidated statements

Those who have already received or will receive the… sadder within the next 2 weeks must pay off their obligations within 30 days or alternatively bring an adversarial appeal as direct appeal to the courts is prohibited.

The rule under the law says that if by December 31, 2023 no tax assessment notice has been sent for 2017 cases, then the case is barred. However, there are exceptions that significantly extend the limitation period up to 10 years. Based on the instructions given by Mr. Pitsilis, these cases are summarized:

1. The five-year statute of limitations is extended by one more year if, within the fifth year of the statute of limitations, an initial or amending declaration has been submitted, or new information comes to the knowledge of the Tax Administration in a case that has been fully audited or information from any source outside the Tax Administration , from which a tax debt arises. This provision applies to tax years, periods, cases from 1.1.2019 onwards.

2. For tax years, periods, cases from 1.1.2014 to 31.12.2018 the five-year period is extended by 1 year if the taxpayer submits an initial or amending return within the fifth year of the limitation period.

3. For tax years, periods, cases from 1.1.2018 onwards, an act of administrative, estimated or corrective tax determination may be issued within 10 years from the end of the year in which the deadline for submitting the declaration or the last declaration to case where the submission of several declarations is envisaged if:

– the taxpayer has not submitted a return

-after the five years, any Tax Administration Service becomes aware of new facts or information that could not have been known to it within the five years and it appears that the tax debt exceeds that which was determined based on a previous direct, administrative, estimated or corrective tax determination and only for the matter to which they relate.

4. For the 2012 and 2013 fiscal years and the 2014-2017 tax years, tax assessment documents can be issued within 10 years from the end of the year in which the deadline for submitting a declaration expires, for cases of tax evasion. For information that comes to the knowledge of any Service of the Tax Administration and concerns tax evasion, tax determination acts are issued only if it concerns tax amounts that exceed the limits set for tax evasion. In the event that information on tax evasion comes to the knowledge of any Tax Administration service after the five-year period, tax assessment notes and fines are issued exclusively for the taxable material resulting from this information and for the year to which they relate.

5. In the event that after the termination of unaudited uses based on special provisions of the law or after the issuance of the initial act of tax determination and within five years, from the end of the year in which the deadline for submitting the initial declaration expires, they come to the knowledge of the Tax Administration new elements, the relevant acts of tax determination and fine imposition, based on termination or on the basis of an audit carried out before 1.1.2014 or on the basis of a full audit carried out from 1.1.2014 onwards, must be issued on a case-by-case basis within the five-year period statute of limitations. If additional information comes to the knowledge of the Tax Administration during the last year of the initial (five-year) statute of limitations, the right of the Tax Administration to issue a tax assessment is extended by one year. This provision covers tax years, periods, cases that ended until 31.12.2013, as well as tax years, periods, cases from 1.1.2014 onwards.