A new regime for tax office fines is coming into force for thousands of taxpayers and businesses that have already submitted — or will submit in the future — late tax declarations.
The Ministry is amending a long-standing flaw in the Tax Procedures Code by drastically limiting the cases in which administrative fines of €100, €250, or €500 are imposed for failure to file a declaration.
The exemption will cover taxpayers who, as is often revealed through cross-checks by the Independent Authority for Public Revenue (AADE), neglect to submit a declaration — or later rush to submit it after the deadline — provided that no tax is due or the amount owed is very small.
End of “heavy” fines for procedural omissions
The main reform introduced (through Article 37 of the law) is that the tax administration will no longer automatically impose fines on those who fail or delay in submitting certain declarations.
The provision does not abolish penalties for late declarations altogether. However, it rationalizes or removes fines for procedural violations that have no revenue or fiscal impact.
The changes take effect immediately following the publication of Law 5301 on May 15, 2026. Moreover, for those who have already paid such fines, the law states that the state will refund them retroactively, dating back to 2024.
Who will avoid fines
Under the new framework, according to Article 37 of the law now in force, fines will no longer be imposed for the following main categories:
- Late initial income tax declarations when the tax assessment is zero or results in a refund, as well as when the payable tax amount is up to €100.
- Late initial “informational” declarations whose submission does not create a tax payment obligation.
- Late initial or amended declarations for indirect taxes, duties, or contributions (excluding VAT and property transfer tax) when the payable tax does not exceed €100.
- Late withholding tax declarations (excluding gambling tax declarations) if the amount due does not exceed the same threshold (€100).
In addition, fines will not be imposed on late declarations submitted on behalf of minors, or by adults for obligations relating to years in which they were minors. The exemption also covers a parent’s income declaration insofar as it concerns income earned by a minor child that is added to the parent’s income.
For late initial VAT declarations, the fine remains in place. However, if no tax is payable, the fine is reduced to €100 instead of the previous €250 or €500, depending on the category of professional or business. In addition, the €100 fine for special VAT regimes is abolished.
The exemption also applies to amended declarations submitted by taxpayers to correct errors in the original filings. Fines will not be imposed in cases of:
a) A late amended income tax declaration by a natural or legal person, if the additional tax payable compared with the original declaration is up to €100.
b) A late amended VAT declaration or withholding tax declaration, provided that the original declaration was submitted on time.
Refunds and retroactive effect for two years
The new rules will apply retroactively from April 19, 2024. However, for those who have already had fines assessed and paid, the money will not remain with the tax office but will be refunded to them.
For this purpose, instructions are expected from AADE on how fines issued during the past two years will be canceled or reduced, and how amounts already paid will either be refunded or offset against other liabilities.
In practice, if by the time the law comes into force a fine has not yet been imposed or collected for such violations, the process will stop. These amounts will no longer be pursued for collection.
A similar process is expected in cases where the fine is not completely erased but merely reduced (to €100 instead of €250–500 for VAT declarations). The fine assessment act will be amended, the debt recalculated, and any excess amounts returned or offset.
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