August's Monthly Tax Briefing covers recent developments in tax legislation, in relation to Circular E. 2055/2025 and Circular E. 2059/2025.
A. Circular E. 2055/2025 on Payments of Debts to the State
B. Circular E. 2059/2025 on Administrative Fines under the Tax Procedure Code
By way of Circular E. 2055/2025 (Circular) the Independent Authority of Public Revenues (IAPR) provides instructions for the implementation of par. 5 Article 25 of Law 1882/1990 ('Criminal offense of non-payment of debts to the State and third parties'), as replaced by Art. 227 of Law 5193/2025.
The new provision introduces favourable measures for taxpayers accepting settlement arrangements with the Greek State.
In particular, the Circular stipulates that, in the event of:
a. submission to a debt settlement arrangement; or
b. suspension of debt collection,
criminal prosecution shall be suspended for the duration of such arrangement or suspension of debt collection. In addition, if the debt is fully repaid, criminal liability is abolished. Furthermore, the Circular sets out:
a. the procedural framework applicable at various stages1;
b. the obligation to notify the Prosecutor in the event of failure of the settlement, and
c. the suspension of the statute of limitations of the offense during the period of the settlement.
The new provision extends the scope of application by providing clarity with regard to the procedural steps and enhancing the incentives for entering into settlement arrangements and for repayment of debts.
Main innovations introduced by the new provisions:
a. The grounds for suspension of criminal prosecution, as well as for postponement or interruption of the execution of an imposed sentence, are expanded. Pursuant to the new provisions, such legal consequences arise not only when debts are included in a settlement arrangement but also when collection of debts is suspended.
b. For the first time, entering into an installment-based repayment arrangement provides grounds for the IAPR not to submit a request for criminal prosecution to the competent Public Prosecutor. Nevertheless, the nature of the criminal offense under Art. 25 of Law 1882/1990 concerning the non-payment of debt to the State, remains. The obligation not to submit a request for criminal prosecution also applies when all debts are subject to suspension of collection.
By way of Circular E.2059/2025 the IAPR clarifies the imposition of fines for procedural infringements under the Tax Procedure Code (TPC).
Article 53 TPC specifies infringements relating to the failure to file or the late filing of tax returns and informational returns, as well as the failure to provide information requested by the Tax Administration. It also establishes the corresponding penalties.
Article 65 TPC regulates the issuance and notification of fine-imposing acts, as well as the procedure for their payment. In addition, it sets out the sanctions applicable in cases where multiple infringements occur concurrently.
In this respect, Circular E.2059/2025 provides further details on issues relating to the non-filing or late filing of tax and informational returns, as well as the failure to provide information requested by the Tax Administration.
1 Prior to or subsequent to the submission of an application to the Prosecutor, prior to or subsequent to the criminal prosecution.
