According to the recent no. 2934/2017 resolution from the Council of State, data from taxpayers’ bank deposits cannot be regarded as “supplementary” taxation evidence, regardless of whether they prove that income has been acquired, in order to justify the issuing of a supplementary audit reports or to extend the audit period limitation.

Based on the rationale of the resolution, these data cannot be considered as supplementary ones, either because they were known to tax authorities, within the foreseen by law limitation of five years, and were ignored, or they were not taken under consideration or tax authorities should have taken them into consideration, within the aforementioned period, if they had shown the appropriate diligence.