The Independent Authority for Public Revenue (AADE) has embarked on a race against time to prevent the statute of limitations from expiring on thousands of tax cases set to close definitively on December 31, 2025. These involve tax cases from 2009 to 2021 where AADE audits have not been completed.
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Greek tax authority races to close cases before 2025 deadline
According to tax legislation, the general rule is that cases expire after five years from the year following the deadline for filing tax returns. However, this deadline can be extended up to ten years in cases where “supplementary evidence” is found – new data indicating tax evasion. In even more serious cases where no tax return was filed at all, AADE’s audit authority extends to fifteen years.
Focus on 2021 cases
Special emphasis is placed on cases from tax year 2021, which was the first full year of implementation of the electronic myDATA books system. For businesses maintaining these books, the law provides for a three-year statute of limitations, provided there are no indications of tax evasion. This means that if a business has regularly submitted its data through the platform, AADE must complete the relevant audit by December 31, 2025 at the latest. Otherwise, the case closes permanently and cannot be re-examined.
Targeting high-value income and asset cases
AADE primarily targets high-value income or asset cases where the fiscal impact is greater. Audit services have digital tools and databases at their disposal that allow them to cross-reference incomes and deposits, identify discrepancies, and initiate tax compliance procedures. They also utilize information from data exchange with tax authorities in other countries, particularly for taxpayers who have moved capital abroad.
