Legal entities tax amnesty: waiver of ancillary tax liabilities related to principal tax liabilities with due date 31.08.2024

This applies to:

• Budgetary obligations with due dates or payment deadlines met by 31 August 2024;
• Differences established by tax decisions communicated by 31 August 2024, as well as those related to tax inspections for which the tax decision was not issued by 6 September 2024;
• Budgetary obligations resulting from the submission of the rectifying tax returns or for tax returns submitted after the legal deadline, starting with 1 September 2024, for tax obligations with maturities before and including 31 August 2024;
• Ancillary obligations related to principal tax liabilities due before and including 31 August 2024, that have been settled by this date;
• Other budgetary obligations included in enforceable titles.

Considering this, we recommend analysing:

• Voluntary compliance with tax matters related to periods up to and including 31 August 2024, without bearing the adverse effects of ancillary tax liabilities (e.g., correcting errors in prior tax returns, addressing different interpretations of tax regulations, mitigating or eliminating tax risks related to previous tax periods, etc.)
•  Recovery or cancellation of ancillary tax liabilities imposed for principal tax liabilities due up to and including 31 August 2024.

Our tax expertise to your advantage

Forvis Mazars specialists can support you with the following:

• Assessing your tax situation by analysing the taxpayer file to identify potential benefits of applying the tax amnesty, and determine implementation methods (tax receivables, offsetting outstanding debts, ways of settling current debts);
• Analysing tax decisions issued by tax authorities for tax liabilities due by 31 August 2024, of ancillary obligations settled by 31 August 2024, as well as of the possible tax obligations subject to payment rescheduling;
• Evaluating the company's tax position to identify past non-compliance issues or ongoing concerns and suggest actions to mitigate these issues and rectify the company’s tax position. Such an exercise will have a dual effect through mitigating any non-compliance areas before a potential tax audit and benefit from the waiver of ancillary tax liabilities generated by rectifying tax returns;
• Reviewing intercompany flows for past tax periods and performing a retrospective adjustment, if necessary, to comply with the arm’s length principle.

Act now to benefit from this tax amnesty - deadline November 25, 2024

The tax amnesty can be applied up to and including 25 November 2024, subject to the following conditions:

• All outstanding principal budgetary obligations due by 31 August 2024 are settled up to and including 25 November 2024;
• All tax liabilities due between 31 August 2024, and the waiver request submission date are settled (however, no later than 25 November 2024);
• All tax returns are submitted;
• The waiver request is submitted by 25 November 2024.

 If the above is of interest to you, please do not hesitate to contact us

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