By Vangelis Dourakis

It is “saved” by the government’s debt with debts of more than 100,000 euros, under the provisions of Law 5193/2025: Under the forecasts of the new law, the prosecution of those who owe large sums to the state, if they are “first arranging them to” arrange them “. To date, the Tax Office has even reserved the right to exercise regular prosecutions in this case in order to secure its interests.

In a circular, AADE, and in particular O. 3018, makes it clear that if one regulates and serves his debts, criminal prosecution will be suspended for as long as the regulation lasts and will be eliminated. If, however, it stops paying, then the ‘upside -down’ judicial procedure will move.

What is the new provision concerned

This provision applies to debtors who do not pay the tax administration certified to the public, public law, businesses and organizations of the wider public sector for a period of more than four (4) months, provided that the total debt from each reason, including each other, including any taxpayers, Debit, exceeds one hundred thousand (100,000) euros.

It also refers to natural persons, legal representatives or members of debtors-lawful persons, who have criminal responsibility for the above crime in accordance with article 25 of Law 1882/1990.

In particular, in the event of- subjecting to the payment of a financial debt of more than EUR 100,000, in accordance with a law or by a judicial decision or by decision of an administrative body or suspension of debt collection, the criminal proceedings shall be suspended for as long as the settlement shall be suspended or the suspension shall be suspended, and in the event of a full payment.

For the same reasons, the execution of the comprehensive sentence is postponed or the execution of the one began, which is eliminated in the event of a full repayment.

Of course, in the event that the debtor loses the arrangement, the Tax Office shall not immediately inform the competent Public Prosecutor, submitting the up -to -date debt of debt.
However, as long as the payment of debts or the suspension of debt collection lasts, the limitation of the criminal offense shall be suspended, by way of derogation from Article 113 of the Criminal Code (and not completed before one (1) year after the expiry of the suspension. interrupted.

What does the new law say

All this is recorded in Article 227 “Criminal offense of non -payment of debts to the State and third parties – replacement of par. 5 article 25 of Law 1882/1990” of Law 5193/2025.

Article 227 of the notified law replaced para as follows:

“5. a) In the case of: aa) Submission of the payment of financial debts in accordance with a law or by a court order or by an administrative or AB) suspension of debt collection, the criminal proceedings shall be suspended for as long as the regulation lasts or the suspension of recovery is in force, and in the event of a full repayment.

For the same reasons, the execution of the comprehensive sentence is postponed or the execution of the one began, which is eliminated in the event of a full repayment.

b) If the arrears shall be subject to any debt payment arrangement in accordance with the first subparagraph of (a) prior to the expiry of the period referred to in para

If the period of the first subparagraph of para.

If the prosecutor has already been filed with the Prosecutor of the Court of First Instance and has not been prosecuted, the competent bodies shall inform the Prosecutor of the Court of First Instance, and if a criminal prosecution has already been brought, then it ceases by a court decision.

c) If the debtor loses the arrangement referred to in (a) and (b), the Administration shall immediately inform the competent Public Prosecutor, submitting the up -to -date debt of debt.

d) As long as the payment of the debts referred to in this paragraph or the suspension of debt collection shall be suspended, the limitation of the criminal offense shall be suspended, by way of derogation from Article 113 of the Criminal Code (Law 4619/2019, A 95) and is not completed before one (1) year. In addition, the execution of the sentence, which was imposed in accordance with this Article, or, if its execution, is interrupted, is postponed. “