AADE: Which 2015–2017 cases close without a new assessment
Circular E.2072/9.11.2026 provides instructions for older tax evasion cases being audited under a specific transitional provision of Law 4646/2019.
The AADE circular concerns specific tax evasion cases for the 2012–2013 accounting periods and the 2014–2017 tax years. The instructions concern the transitional ten-year limitation period under the second sentence of Article 66, paragraph 27a, of Law 4646/2019. The authority issued the instructions following Council of State decision 1246/2026, as it describes that decision in the circular.
For pending 2015–2017 audits relying on this provision, corrective tax assessments or penalty decisions are neither issued nor served, even if a provisional assessment has been sent or decisions have been issued but not served.
The competent head of the audit service informs the taxpayer by email that the case relating to the specific audit order has been closed.
In these cases, amounts assessed or paid by the time the circular was issued are not automatically cancelled or refunded. The relevant decisions must be annulled or amended by a decision of the Dispute Resolution Directorate (DED) or the administrative courts.
The instructions concern this specific transitional rule. They do not constitute a general change to limitation periods or mean that every case older than five years has been closed.
Closing the specific tax audit does not remove the separate obligations to submit criminal complaints and anti-money-laundering referrals in the circumstances specified in the circular. The effects of accepting assessments under Article 75 of Law 5104/2024 also remain in place where the required payment conditions are met.
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