Greece: New code of tax procedures revises tax system

The Greek government has introduced a new code of tax procedures through Law 5104/2024, which aims to simplify and modernize the Greek tax system. The main revisions include:

• Digital notification of administrative acts and documents: Notifications will primarily be made digitally and will be considered legally served to the taxpayer after 10 days from the date of its posting on the taxpayer’s account and its notification by email.
• Suspension of tax identification number (TIN): The use of a TIN can be suspended in cases of bankruptcy, insolvency, cessation of economic activity, or serious offences such as tax evasion, smuggling, or fraud.
• Provision of information by the taxpayer: Taxpayers must provide requested information within 10 days, and those who keep simplified books are no longer obligated to submit their books to the tax authorities.
• Submission of late/amended tax returns: These can be submitted until 10 days after the preliminary tax assessment note is served.
• Transfer pricing documentation file: Companies and branches of companies subject to Law 89/1967 are exempted from the obligation to document their intra-group transactions. While this exemption is not new, it has now been incorporated as a provision of the law.
• Duration of tax audits: A specific time frame of up to one year is set for the completion of tax audits, with the possibility of extending it only once for six months.
• Interim tax assessment: The tax administration may carry out an interim tax assessment based on available information when exceptional circumstances occur.
• Automatic tax assessment: The tax can be determined by means of a tax return, which will be automatically pre-filled based on all the information available to the tax administration.
• Statute of limitation: Within the five-year statute of limitation period, the tax assessment note should be issued and served to the taxpayer.
• Acceptance of tax audit acts: Penalties can be reduced if the taxpayer accepts the results of tax audits at some stage of the tax audit procedure.

The new code of tax procedures is applicable as of April 19, 2024, with some provisions coming into effect later in the year.

Read a June 2024 report prepared by the KPMG member firm in Greece