In the past year, the Greek tax authority published a series of legislative acts introducing new requirements (the QR code and prefilling of VAT returns) and amending existing ones. It’s been more than three years since the rollout of myDATA as a voluntary scheme, but the system is far from complete.
myDATA is a broad and multi-faceted project covering multiple areas of compliance, ranging from e-invoicing to e-accounting and e-bookkeeping. The system, being quite complex, is still largely under development, technically and legislatively, and prescribed deadlines keep receiving push-back from businesses not ready to comply in time.
myDATA Deadlines Postponed
In response to continuous feedback from businesses and accountants the tax authority more than once has relaxed requirements, offered grace periods and imposed no associated penalties so far (except certain petty fines for 2021 related to recapitulative statements).
One of the latest amendments is the second postponement of transmission deadlines for certain, mainly historical, data which ought to have been reported in the past two years. The Ministry of Finance jointly announced a press release with the head of the IAPR and published a Decision amending the myDATA law (L. 1138/2020). The deadlines for transmitting certain data generated in 2021, 2022 and 2023 are postponed, giving businesses more time to collect and transmit data according to the myDATA specifications.
myDATA reporting deadlines 2023
For 2023, the obligations pertain to the transmission of historical data which took place in the last two years. Current data generated in 2023 may be transmitted within certain deadlines in 2024.
- Revenue, self-billing expenses, and proof of expenditure which took place in 2022: transmission must be by 31 March 2023
- Expenses and self-billing revenue which took place in 2022: transmission must be by 31 October 2023.
- Omissions (the obligation of the receiver to transmit the data that the issuer failed to transmit) and discrepancies (the obligation of the receiver to send discrepancies when the issuer sent incorrect data) which took place in 2022: transmission by the recipient must be by 30 November 2023
- Omissions and discrepancies which took place in 2021: transmission must be by 2 May 2023.
- Accounting (adjustment) entries for revenue and expense which took place in 2022: transmission must be by 31 December2023
- Retail FIM (electronic cash mechanisms) income via ERP or myDATA’s Special Registration Form: transmission must be by 31 October 2023. From 1 February 2023 transmission of data must be directly through FIM.
myDATA reporting deadlines 2024
For 2024, the obligation pertains to upcoming data which take place in 2024. Current data generated in 2023 may be transmitted within certain deadlines in 2024.
- As of 1 January 2024: obligation for entities to transmit all the data in scope of myDATA which took place in 2024 in the standard deadlines as outlined in the myDATA Law
- Revenue which took place in 2023: reported by 28 February 2024
- Expense data, self-billing revenue which took place in 2023: transmitted by 31 March 2024
- Omissions and discrepancies which took place in 2023: transmitted by the recipient can be by 30 April 2024
- Accounting (adjustment) entries for revenue and expense which took place in 2023: reported by 30 June 2024 (the deadline for filling annual income return)
myDATA next steps
The tax authority’s intention with these changes is to provide more time for businesses who haven’t complied with the previous transmission deadlines to report the required data to myDATA. However, starting from January 2024 the tax authority is expecting businesses to comply with the required deadlines without providing a grace period, at least as of yet.
Certain major aspects of the myDATA system have been the center of much discussion among businesses, accountants and the authorities. This includes mandatory reporting of expense data and any penalties relating to 2022 and onwards which are currently left unregulated. However, the tax authority has announced that a decision regarding the penalties will be published in the next months.
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