With the implementation of the Law 4337 / 2015 major changes were made in the Tax penalty sanctions, in regards to the Intercompany transactions, we had the following changes:
- For the late submission (beyond four months), or inaccurate submission of the summarizing Information Table, a penalty of 1/1000 of the amount of the Transactions is imposed, with a minimum amount of € 500,00 and maximum amount of € 2.000,00 (in the previous law the maximum penalty was € 10.000, 00).
- For the late submission of an amended summarizing Information Table, the same penalty is set only if the amounts of the transactions which have been amended are higher than € 200.00,00.
- For non-submission of the Information Table, a penalty equal to 1/1000 of the amount of the transactions is set of a minimum amount of € 2.000,00 and maximum amount of € 10.000,00 (in the previous law the maximum amount was € 100.000,00).
- For the late submission
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- Submission to the Tax administration later than the 31st day, penalty € 5.000,00
- Submission to the Tax administration later than the 61st day, penalty € 10.000,00
- Submission to the Tax administration later than the 90th day, penalty € 20.000,00
- No submission of the Transfer Pricing Documentation, penalty of € 20.000,00
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NOTE: This article does not cover advisory, but only informational purposes, and cannot serve, as a basis for further actions, on the part of the reader. Reception of specialized advice is required.
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