Amendments to tax regulations – Year 2025 – Part 4

24. January 2025.

As of January 1, 2025, amended tax regulations in the areas of local taxes, personal income tax, contributions, value added tax and general tax came into force. Below, we present the most significant amendments to the tax regulations.

General Tax Act

  • In case of failure to submit the prescribed monthly or annual tax returns, the liability of the company member is also determined in the tax decision procedure. Company members are jointly liable for the determined liability, as guarantors for payment, and an appeal against the tax decision does not delay its execution.

  • The delivery of tax acts and other documents that are not tax acts issued by Tax Administration is adapted to electronic communication, and it is prescribed that the participant, by registering or applying to the tax authority’s electronic system, gives explicit consent for the delivery of documents electronically.
  • The obligation to submit tax returns or other data necessary for taxation through eTax system is extended to individuals and legal entities subject to corporate income tax, those earning income from self-employment, individuals earning income from rental of houses, apartments, rooms and beds, as well as from accommodation facilities for tourists and travelers, camp organizations, and members of crew in international maritime navigation.
  • The possibility of entering into an administrative agreement with the Tax Administration through an electronic service is introduced. Furthermore, a proposal for concluding an administrative agreement with the Tax Administration for tax debt up to EUR 10,000 does not need to include a proposal for a security measure for debt collection.
  • The statute of limitations for the right to collect tax liabilities, interest, and enforcement costs does not run in cases where the Tax Administration was unable to initiate collection because the taxpayer has no right to a refund of paid taxes or interest on customs payments if the payments were made after the statute of limitations has expired.
  • Tax supervision can begin within three years from the start of the statute of limitations for determining tax obligations, and the cases in which tax supervision can be carried out within six years from the start of the statute of limitations for determining tax obligations have been expanded. In the case of a tax audit notice, the factual basis as a mandatory element has been removed, and due to the digitalization and informatization of the tax audit procedure, it is prescribed that the tax audit report is issued in electronic form.
  • In the case of the write-off of overdue tax debt, there must be a confirmed restructuring plan in pre-insolvency proceedings that states the debt will be written off. Regarding the seizure of monetary funds from the debtor’s accounts, the regulation now prescribes that the enforcement decision based on an enforceable or credible document will be executed immediately by the Financial Agency upon the enforceability of the decision.

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Please keep in mind the fact that legislation tends to change frequently. This article is therefore necessarily based on our understanding and correct interpretation of the law and practice at the time of issuing this article. This article will not be updated due to changes in legislation that occur after this article is issued.