Special framework of obligations and sanctions, designed to ensure that the Tax Administration will have a complete and accurate picture of real estate and its use, with the launch of the Real Estate Ownership and Management Registry (MIDA) in early July.

As provided for in an amendment by the Ministry of National Economy and Finance (YPETHOO) incorporated into the omnibus bill, in cases where the details are not correctly declared, as well as the use of the real estate in the digital registry, owners will face fines of up to 1,000 euros.

Changes are also coming to the ENFIA, from which the state collects approximately 2.3 billion euros per year. The tax will be levied on the actual floor area of properties, based on the Electronic Building ID.

Owners, landlords, and concessionaires are required to declare the use of the property in a timely manner, while tenants and concessionaires are responsible for the accuracy of the information they provide, particularly when it relates to receiving benefits, aid, or subsidies.

Specifically, in cases of property leasing or free concession, specific fines are imposed for failure to submit or for submitting inaccurate usage information.

The “fines”

  • As part of the MIDAS reporting process, the liable party must submit an informational declaration regarding the use of the property. If this declaration is not submitted within three months of the start of the lease or the free transfer a fine of 500 euros is imposed.

Obviously, the 500-euro fine will mainly apply to owners, lessors, or grantors who fail to declare the use of the property to M.I.D.A. in a timely manner.

  • A specific deadline is also set for cases related to the Single Aid Application.

The declaration to update M.I.D.A. must be submitted within two months of the start of the submission period for the Single Application for Aid. If this specific deadline is not met, a fine of 500 euros will also be imposed .

  • For providing incorrect information  (in addition to failing to submit the declaration), penalties apply exclusively to the tenant or concessionaire—that is, the person using the property. If the tenant or concessionaire submits a declaration of use containing inaccurate information and that declaration is used to grant benefits, aid, or subsidies, or a rent refund, a fine of 1,000 euros is imposed. The penalty is more severe because the inaccurate declaration is linked to a financial benefit or the ability to receive public assistance.
  • A lower fine (100 euros) applies in cases where the declarations contain incorrect information but this information has not been used to grant benefits, aid, or subsidies.

The provision also stipulates that when an informational declaration regarding the use of real estate is required, a real estate information declaration (E9) must have been submitted beforehand.

Consequently, before declaring the property’s use to MIDA, the property’s basic details must be up to date.

ENFIA with an “ID”

Starting in 2027, the Electronic Building ID will also be taken into account when calculating ENFIA, so that the tax is calculated based on the actual floor area of the buildings.

Currently, ENFIA is determined based on data from the Land Registry, the title deed, or the building permit.

If the actual area of the property is greater than that listed in the Land Registry, in the title deed or the building permit, or if the use of the property has changed, then the tax is calculated based on the actual area and the actual use.

Specifically for buildings for which an Electronic Building ID has been issued, if the actual area is smaller than that listed in the Land Registry, in the title deed or the building permit, the area indicated in the Electronic Building ID will be taken into account.

No penalties will be imposed

The provision further stipulates that E9 declarations, ENFIA assessment notices, and ENFIA certificates that have already been issued are not considered inaccurate, nor are penalties imposed in cases where the actual area, as evidenced by the Electronic Building ID, is smaller than that listed in the Land Registry, the title deed, or the building permit. The same applies to ENFIA certificates that have already been issued.

Tax Evasion and Organized Crime

Another amendment submitted to the same bill fast-track procedures are introduced for tax audits and criminal prosecutions in cases of large-scale tax evasion linked to organized crime.

The goal is the rapid identification and dismantling of networks that, according to the rationale behind the regulation, conceal their actual profits through corporate front networks and straw men. The focus is on close cooperation between the Directorate for Combating Organized Crime and the Independent Authority for Public Revenue, which are now able to initiate proceedings almost “in real time.”

In serious cases, provisional taxes and fines are even imposed before the full investigation is completed, and these are included directly in the case file. At the same time, criminal proceedings can be “frozen” until tax decisions are finalized, creating a system where audits and prosecutions proceed simultaneously and more quickly.