The retroactive implementation of the articles of 15 para 3 of Law 3888/2010 and 48 para 3 of Law 2238/94 in case of an audit over the asset increase
by Theodoros P. Fortsakis, Professor of Law School of National Kapodistrian University of Athens, former Dean of National Kapodistrian University of Athens
and Petros G. Pantazopoulos, PhD, National Kapodistrian University of Athens, NCSR, Associate Professor
Published in “Business & Company Law” Issue 5/2015
It is well known that paragraph 3 of Article 15 of Law 3888/2010 provided that taxpayers shall justify any increase to their property in order to avoid a relevant added tax. The provision is as follows:
“In case of an asset increase from an unknown or uninterrupted or unstable source or cause, the taxpayer may be required to prove that a) the true source or cause of the origin of the increase or b) the taxpayer is taxed by other provisions or c) the taxpayer is exempted by special provisions.”
