On 31.12.2025 they are extinguished for the Independent Public Revenue Authority (AADE) the cases of the tax year 2019 in income tax and VAT, since until then no act of imputation has been notified to the taxpayer.
The AADE mechanism is already running to prevent the statute of limitations and ensure revenue from taxpayer cases with substantial fiscal interest.
The basic statute of limitations is five years from the end of the year in which the return was filed. This means that 2019 years declared in 2020 close at the end of 2025, as long as no deed has been sent. At the same time, targeted audits continue in cases with indications of concealment or error, such as backlogs of wages and pensions that were not declared, income from rents that were not recorded in the E2, remuneration from abroad and discrepancies in the company books.
For special cases, the law allows a longer time horizon. If no declaration has been submitted or “supplementary information” that was not available to the tax administration is obtained, the right to audit is extended up to ten years. In these cases, the statute of limitations for 2019 uses may reach as late as 2030. In addition, the exchange of information with other authorities and countries may shift the time limits when new data is identified.
A critical point for taxpayers is the notification of the transaction. If by December 31, 2025 no charge sheet or fine has been served, the case is considered time-barred and cannot be reopened based on the same data. Conversely, filing a late or supplementary return within the five-year period may affect the statute of limitations by shifting the control limits.
AADE’s business plan prioritizes cases with a high probability of collection and those where cross-checks from payroll, bank transactions, myAADE and myDATA show gaps or inconsistencies. The aim is to send in a timely manner the acts where discrepancies are found, so as not to lose years that close in the calendar of 2025.
In any case, citizens and businesses should check their 2019 declarations, settle any pending issues and have their supporting documents available. Where there are errors that are corrected, early action reduces the risk of charges, while where there are no pending cases, failure to notify an act by the end of the year permanently closes the file.