The Independent Authority for Public Revenue (AADE) has finally issued clarifications on the municipal accommodation levy through a series of questions and answers.
As previously announced by AADE representatives at the ShortStay Conference 2024, individuals operating up to two short-term rental properties are NOT required to pay the municipal accommodation levy.
AADE’s detailed Q&A on the municipal accommodation levy
Q. I am already a registered user of the myAADE service. What do I need to do to file the relevant return?
A. Existing registered users do not need to go through a new registration process. They can continue using the username and password they already have.
Legal entities that have registered for AADE’s online services or have been re-certified must authorize an individual, representative, accountant or accounting firm to file the return through the myAADE authorizations application.
Individuals who have registered for AADE’s online services or have been re-certified must also authorize their accountant or accounting firm through the authorizations application if they wish the returns to be filed on their behalf.
Q. Can I file late returns through the myAADE service?
A. Yes. Initial returns, both timely and late, can be filed for tax years from January 1, 2022 onwards.
Specifically, for outstanding accommodation levy amounts and gross revenues for 2022, as well as revenues for the period from January 1, 2023 to October 31, 2023, the return for the payment of the amounts due must be filed for the total amount owed by November 30, 2023, with payment also due by the same date.
BnB News note: This particular provision does not concern short-term rental properties, as the municipal accommodation levy was introduced for them from January 1, 2024.
Q. Can I file supplementary returns?
A. Yes. Supplementary returns must be filed through the online application. There is no obligation to file a zero return. Revocation returns must be filed with the relevant municipalities.
Q. If I finalize a return and discover an error, can I correct it?
A. No. Once a return has been finally submitted, it cannot be deleted.
If the difference is positive, you can file a supplementary return through the application. If the difference is negative — meaning that you have declared more than the correct amount — you must contact the relevant municipality to have the error corrected.
Q. When is a finalized return considered to have been received?
A. A return is considered to have been received once it has been finally submitted.
Q. What happens if the payment deadline expires without the accommodation levy being paid?
A. In the event of a late return or failure to pay the levy within the applicable deadlines, a surcharge equal to 2% of the unpaid levy is imposed for each month of delay.
Q. When must the return for the municipal accommodation levy and the levy on gross revenues be filed?
A. Where the business is subject to VAT, the deadline for the timely filing of the return is the last working day of the month following the reporting month or quarter, depending on whether the taxpayer keeps double-entry or single-entry accounting books, respectively.
For taxpayers who are not required to file VAT returns, the levy return must be filed by the last working day of the month following the reporting quarter. In other words, the deadline is the same as the deadline applicable to VAT returns for taxpayers using a single-entry accounting system.
IMPORTANT: Where a return is filed late, the surcharge is calculated up to the date on which the return is filed.
Q. Is the filing of initial and supplementary returns for the municipal accommodation levy and the levy on gross revenues now mandatory through electronic communication?
A. Yes. Returns must be filed through myAADE, whether they are timely or late.
Q. How are initial returns filed through the application?
A. The user selects the year and the calendar period. On the return screen, the user selects the municipality, the type of establishment/business and the type of revenue, enters the relevant amounts, and the system calculates the amount due.
If the taxpayer has more than one type of establishment or business in the same municipality, the system allows additional activities to be entered by clicking the “+” button. Additional municipalities can be added by clicking “+ Municipality”, where the taxpayer has branches in different municipalities.
The return is finalized by clicking the “Submit” button twice.
Once the return has been submitted, the amount due is displayed immediately, allowing the taxpayer to pay it at once, if desired. Immediate crediting of the payment avoids waiting for the transfer of the payment from the taxpayer’s bank to AADE.
Q. Can I save the return and finalize it later?
A. Yes. From the moment a return is created, the user can temporarily save it at any stage before submission by selecting “Temporary Save” from the menu.
The return will then appear as temporarily saved in the search function, allowing the user to review and submit it later.
Q. How are supplementary returns filed through the application?
A. The user selects the year and the calendar period. The screen indicates whether an initial return has already been filed.
Among the saved returns for the selected period, the user can file an amended return. The return page displays the details of the most recent submission, including the municipality, the type of establishment/business and the amounts declared.
If the user wishes to correct or add a type of establishment/business in the same municipality, the system allows the incorrect entry to be edited by entering the correct amount.
To add an activity that was omitted, the user clicks the “+” button.
To add a municipality, the user clicks “+ Municipality”.
To change the amount for an activity that has already been entered, only a higher amount can be declared. The total amount of the amended return cannot be lower than or equal to the amount declared in the initial return.
The return is finalized by clicking the “Submit” button twice. A return reflecting the difference between the initial and amended amounts is then created.
EXAMPLE
The following example illustrates how the application works and concerns amounts after the deduction has been made.
Suppose that, in the initial return filed by a business for 2022, the following amount was declared:
Athens Municipality – accommodation revenue: €15,000.
The municipal accommodation levy (0.5%) is:
€15,000 × 0.5% = €75.
Once the return is finalized, a €75 liability is automatically assessed against the business’s tax identification number (AFM), and a Payment ID is issued.
If the business made an error in its initial return and should instead have declared:
Athens Municipality – accommodation revenue: €35,000.
The municipal accommodation levy (0.5%) is:
€35,000 × 0.5% = €175.
The business must then file an amended return. In the existing entry from the initial return, it must correct the amount from €15,000 to the correct amount of €35,000.
Once the amended return is finalized, a Payment ID will be issued for the difference of €100 (€175 − €75), and the additional €100 levy will be assessed against the business’s tax identification number.
IMPORTANT
As of January 1, 2024, under paragraph 5A of Article 111 of Law 4446/2016, as amended by Article 28 of Law 5073/2023, businesses whose activity consists of providing short-term rental services through digital platforms within the sharing economy — namely, individuals operating three or more properties and legal entities — are required to charge the municipal accommodation levy.
