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Tax Procedure Code

Law 5104/2024

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The Tax Procedure Code governs the relationship between the taxpayer and the Tax Administration: the assessment of taxes, their collection and the applicable sanctions. Until the Tax Procedure Code there was no single body of rules, and each tax had its own procedural provisions. The first Tax Procedure Code (Law 4174/2013) unified those rules for almost all taxes; today, Law 5104/2024 is in force.

Questions such as when a deadline starts to run, or whether the limitation period has expired, are often decided on technical details of the procedure — details that can prove decisive for the outcome of the case.

Typical cases

  • Limitation of the Tax Administration's power to assess and to collect
  • Review of the lawfulness of service of the acts and of when the relevant deadlines start to run
  • Challenging fines and other sanctions
  • Requests for annulment or amendment of an act for manifest absence of tax liability or arithmetical error
  • Debt settlement arrangements, tax clearance certificates and measures safeguarding the interests of the State