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The information and / or opinion offered in this section is merely informative and orientative, and should not be considered legal or tax advice of any kind.

Jurisprudential interpretation of the concept of prior requirement

The recent Judgment of the Supreme Court of November 23, 2020 (No. 491/2019) has resolved an issue of great interest in tax matters: the scope of the concept of “prior requirement” for the purposes of imposing the surcharge of Article 27 of the General Tax Law, (hereinafter, LGT) for the presentation of an extemporaneous declaration “without prior requirement” or, where appropriate, of the corresponding sanction when it has been made “with prior requirement”.