The “bell” rings AADE to the auditing authorities, in order to… quickly dust off pending cases of the past and not to lose thousands of income tax, VAT, real estate cases, which after December 31, 2024 pass to the “fireproof”. The control mechanism, which has already been mobilized, is expected to send the first… bills to around 20,000 in September taxpayers for pending income tax, VAT and real estate cases of 2018.

The audits, in the first phase, focus on pensioners and employees with undeclared retroactive amounts, taxpayers with earnings from abroad, property owners with undeclared income and freelancers. It should be noted that priority is given to the unaudited tax cases of the year 2018, which are the first to be statute-barred at the end of this year, unless of course there are additional elements, which under the legislation extend the statute of limitations to 10 years, or other data, such as the submission or not tax returns that modify the limitation periods.

5-year deadline

In any case, however, the files of all the cases have already been forwarded to tax authorities and Audit Centers, in order to carry out the required checks and then to remove the notices with the… account, since the whole process must “run” based on the decision of the Council of State, in which it is stated that the State’s right to impose taxes and fines is lost if it does not notify the taxpayer of the assessment act within the prescribed period of limitation.

By another decision of the Supreme Court, within the five-year limitation period, a supplementary control sheet or act of corrective determination may be issued if, after the submission of the income tax return, additional information revealing the concealment of taxable material comes to the knowledge of the competent tax authority. Such additional data, according to the SC, are the movements and balances of the bank accounts, while they are considered essential for carrying out additional checks by the tax authority only when they reveal the concealment of taxable material, which of course constitutes a violation of the tax legislation.

It is noted that even after the initial submission of the income tax return, the tax authority has the right to revise its assessment and proceed with additional imputations, provided, however, that the relevant bank details obtained after the submission of the return substantiate the issuance of a supplementary control sheet or act of corrective determination.

G.K.

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