Following the issuance of the last relevant decision by the Supreme Court, the rules that apply for the limitation of income tax and VAT cases are as follows:

The normal limitation period is five years. The five-year period starts immediately after the end of the year in which the relevant tax return has to be submitted.

 – If, after the expiry of the normal five-year limitation period, the tax authorities find evidence which is regarded as ‘supplementary’ and shows that the taxable amount and the tax paid is lower than it should be and that the tax returns submitted were inaccurate, then the limitation period is extended for another five years and becomes ten years.

– If the tax authorities find that a VAT return has not been submitted for a certain fiscal year, the limitation period for the right to audit the year in question and the imposition of taxes and fines is becoming 10 years, i.e. Ιt is extended by a further five years after the expiry of the normal five-year limitation period.

– If the tax authorities find that for a certain fiscal year no income tax return has been submitted, the limitation period for the right to audit the year in question and the imposition of taxes and fines is 15 years, i.e. Ιt is extended by a further 10 years after the expiry of the normal five-year limitation period.

– If an overdue income tax return is submitted within the normal five-year limitation period of the audit right, the time limitation period is no longer extended, but remains for a period of five years.

– If the overdue income tax return is submitted in the last year of the normal five-year limitation period, the limitation period shall be extended for a further three years, becoming in effect, eight years.

– If an overdue income tax declaration is submitted after the five-year limitation period of the audit right, then a three-year limitation period, starting from the end of the year of submission of the late submission, is in effect. However, the maximum limitation period may not be longer than 15 years from the end of the period for submitting the tax return.

For the years 2012 and beyond, a 20-year limitation period is provided for the detection of tax evasion. This period shall begin at the end of the year in which the relevant initial deadline is to be submitted.