The text of the letter reads as follows:
To Deputy Minister of Finance Mr. Apostolos Vesyropoulos
KOIN.: To the Governor of AADE Mr. George Pitsilis
Herein Athens, 5.3.2021
SUBJECT: Rent reductions: Initial declarations COVID, submission deadlines and subleases.
Dear Deputy Minister
First of all we would like towarmly thank you for your positive responseto the requests of our organization and in particular your recent announcement of a comprehensive solution to the pending process of declaration and payment of property owner compensations from the ongoing reduction of their rents, on which we point out the following:
1.Initial COVID declarations should also be accepted: The Ministry of Labor has repeatedly given employers and employees the right, often for many months, to retroactively submit a declaration of suspension of an employment contract. Also, many professionals, etc., taking advantage of the opportunity given to them, made retroactive changes to the KAD that would guarantee them a rent reduction. All these workers and professionals throughout the country announced to their landlords that they were entitled to rent reductions, without any deadline, whenever they wanted and at a much later time, when it had already passed for the landlords. the deadline for them to submit a COVID declaration to AADE, arbitrarily withholding the amounts of the reductions from the next rents and ignoring the fact that the owners had missed the deadline and therefore their right to compensation! Also, a number of owners, of advanced age and especially from the region and the Greek diaspora, did not submit COVID declarationsdue to a complete lack of information about these declarations and the very short deadlines for their submission!
Because it is unacceptable for exclusive terms to apply only to landlords, when they do not apply to tenants, it must today be explicitly provided for u> not only the ability to correct submitted declarations, but also the possibility to submit initial declarations COVID, if the legal conditions are met, for all those who missed the shortest deadlines, so that no one loses their legal compensation, due to formal errors and oversights either of the Administration or of the governed.
2.Monthly deadlines for statements-corrections: We point out to you but due to competence and to the Governor of AADE, Mr. Giorgos Pitsili, that sufficient time must be given for the corrections concerning the period of 2020, so that the owners, and especially their tax experts, can first be informed of the errors and then fix them, since there are many other parallel deadlines of many other applications running today. That is why we ask that at least monthly deadlines be set after the update, without any extension.
3.Property subleases. Finally, please clarify explicitly and unequivocally whether it is legal to reduce the rent owed to the owner-original lessor of a property, by his tenant who owns it sublease to a third party who carries out a “closed” or “affected” professional/business activity in it,so as to stop the unilateral and illegal rent reductions by the sublessors at the expense of the property lessors.
Awaiting a positive response for your participation in the POMIDA tax seminar (8.3).
With special regards
The President I. Paradias Tasos G. Vappas Lawyer A.P. – UIPI President Lawyer A.P. – y.D.N.
