To the Commander of AADE Mr. George Pitsilis
Here 6.7.2020
SUBJECT: Request to continue the possibility of declaring March-June rent reduction (COVID) on the AADE platform. – Limitation of unnecessary declarations of lease details.
Dear Governors
A. With your decision no. A 1139/2020 (Government Gazette B’ 3579) “Amendment of POL.1162/2018 decision “Submission of Real Property Lease Information Statement using an electronic method of communication via the Internet”, the implementation of the government’s commitment to tax exemption for owners who suffered forced a 40% reduction in rents due to the coronavirus.
The shortest deadline, however, for taxpayers to catch up on the payment of income tax, and despite the extension granted which ended on 1.7.2020, which was literally suffocating both for your Service, which worked at a literally superhuman pace, as well as for the taxpayers of the country and the Hellenic diaspora, and especially their tax technicians, in combination with the absence of clear statements of “ERGANIS” in the hands of most landlords, and that a frequent prerequisite for the declaration was the initial submission of the old agreements, resulted in a significant number of them not being able to submit the relevant COVID declaration on time!
For this reason, we ask you, in parallel with the opening of the platform for COVID declarations in the following months, to continue the possibility of submitting a COVID declaration for the first four months of March-June, because it would be unfair to deprive these lessors of this tax relief due to the loss of such a suffocatingly short deadline!
B. Also with regard to the obligation to submit lease information statements, please make the following clear in your relevant decision:
*Because the new leases of a main residence or business premises are automatically valid for a three-year period, even if they have been agreed for a shorter time, as the legislation of both categories explicitly states, to explicitly state that there is no need to submit any statement of modification (extension of their duration) to the lease platform.
* Because according to article 611 of the A.K. all new and old leases are automatically converted into open-ended leases if the tenant remains on the lease after the end of the agreed period without objection from the lessor, to explicitly state that here too no submission of a declaration of modification (extension) is required, while, of course, it is not modified the lease or the lease is not terminated.
C. Finally, we ask that the inaccurate title “Property Leases” listed on the AADE website be replaced by the correct “Property Leasing Information Statement”, as you explicitly clarify this from the beginning in your instructions, so that the simple property owner does not misunderstand the submission to the AADE of the information of a lease as a so-called “Lease”, with extremely unfavorable legal and financial results to his detriment.
Stratos I. Paradias Tasos G. Vappas
