Administrative (internal) Appeal
Why are administrative appeals filed?
Litigation appeals are submitted for the review of tax administration deeds in the context of the administrative procedure. The purpose and goal is to resolve tax disputes in the short term, so that to achieve the quickest collection of public revenue and to decongest administrative courts from cases that can be resolved at the level of tax administration.
In which cases and how can I file a complaint before the Dispute Resolution Directorate?
If the taxpayer disputes acts, explicit or implicit, issued or carried out from 1/1/2014 onwards against him by the Tax Authority and falling within the scope of application of the Code of Tax Procedure (article 2 of law 4174/2013) must, before appealing to the Administrative Court, file an appeal before the Dispute Resolution Directorate of the Independent Public Revenue Authority with a request for reconsideration in the framework of an administrative procedure. The administrative appeal is filed to the competent tax authority that issued the contested act.
Within what period can I file an appeal?
The appeal is filed against acts of the tax authorities within a subversive period of thirty (30) days starting from the effect of the notification of the act or the effect of the omission, in accordance with the provisions of article 5 of the Code of Civil Procedure. or respectively of article 63 of the Code of Administrative Procedure. Especially for residents abroad the relevant deadline is set at sixty (60) days.
The appeal is brought:
- For a scholastic inheritance (i.e.estate without a claimant) from the guardian.
- For litigation by the temporary administrator.
- For guarantor by the guarantor.
- For bankrupts by the trustee.
- For a minor by the person exercising parental care or the guardian and in most cases by one of them.
- For a person who is in legal aid by the legal assistant.
- For a deceased taxpayer by his heirs.
