POMIDA TO AADE: NECESSARY CHANGES TO THE SUBMISSION DEADLINES OF COVID DECLARATIONS!

EXTREMELY URGENT

To the Governor of AADE, Mr. Giorgos Pitsilis

Inside Athens, 18.11.2020 strong>

SUBJECT: Necessary changes to COVID filing deadlines

Dear Governors

Following yesterday’s passing in the Parliament of the provision regarding rent reductions in November and from now on, there is an immediate need for improvement changes in the submission process and deadlines “Covid declarations” on behalf of real estate lessors, with an adaptation to this of your relevant decision Pol. 1162/03-08-2018 (Government Gazette B’ 3579/22-08-2018), as amended and in force today.

On this matter, and given that the control and clearing of declarations is time-consuming anyway, there is no justification for setting deadlines of a suffocating nature for both the owners and and their tax experts, nor is it morally permissible to apply exclusive deadlines, which whoever misses them, loses his compensation too! On these issues, our proposals are as follows:

1. Given that many tenants, especially residential ones, inform their landlords with a huge time delay, when the deadline has already expired, and they proceed with the reduction through withholding from subsequent rents, as the deadline for submitting an initial or amending “Covid declaration”, defined in article 11 of the above decision (pol. 1162/03.08.2018) cannot be the “twentieth day of the month to which the reduction concerns”, but the classic deadline of the last day of the following month, as provided in article 1 of the above decision (“1. Real estate lessors are required to declare all the information of the initial or amending leases, until the end of the following month from the start of the lease or the date on which its modification takes place, regardless of whether it is a written or oral agreement”).
2. Additionally for amending (corrective) “Covid statement » should be provided for the possibility to be submitted within another two months, without consequences, for the reason we stated above. 
3. In case of late submission of the initial or amending “Covid declaration” (that is, after the deadlines requested above), the imposition of the classic fine of 100 euros may remain as a sanction, but not the full deprivation of the right to submit the declaration and total loss of the return.
4. The deadline for correcting errors or omissions in the months of March – August of par. 8 of article 11 of the above POL which expires on 15.12 and provides for the possibility of submitting informational declarations and Covid, should be extended until 31.12.2020 and include initial statements for the months up to and including December 2020.
5. The deadline for submitting the COVID statement regarding the optional rent reductions for the months of September and October, which with your decision A.1230/20.10.2020 were set for 20.11.2020, to be extended until 20.12.2020 and accordingly the deadline for acceptance until 27.12.2020. 
6. The deadline for submitting past leases and amending declarations must be extended at least until 31.1.2021, given that you will need the information much later, when you start the process of submitting the 2021 tax returns, for the composition of their content in terms of rents to be declared and only when there is a need for a “Covid declaration”, to be preceded electronically by an initial or amending “Property Lease Information Statement”.  
7. In the “Covid declaration” (article 11 of the decision pol. 1162/03.08.2018), a field must be added to remind or complete the bank account of the taxable lessor if he has not already declared it to TAXISNET, so that avoid unnecessary delays in completing the payment process.
8. Finally, we ask once again that the inaccurate title “Property Leases” listed on the AADE website be replaced by the correct “Property Lease Information Statement”, as after all, you also explicitly clarify this from the beginning in your instructions, so that the simple property owner does not perceive the submission of the information of a lease to the AADE as a so-called “Lease”, with extremely unfavorable legal and financial results to his detriment.  

At your disposal for any clarification and cooperation

The President Gen Secretary