On 15 January 2026, Law No. 86/2025 was adopted, through which taxpayers may benefit from the cancellation, extinguishment, and payment of outstanding tax liabilities, as well as liabilities payable to customs.
Beneficiaries:
– Taxpayers registered in the active, passive, deregistered registers or holding other statuses in the “e-tax” system, for tax liabilities owed to the central and local tax administration;
– Debtor entities towards the customs administration.
Non-beneficiaries:
-Taxpayers/entities who have been convicted by a final court decision or are under judicial proceedings or investigation for criminal offenses in the field of taxation and/or customs, before or during the period of implementation of this law.
Exception! They may benefit if they are in an administrative/judicial appeal process regarding the liabilities and withdraw from the administrative appeal/right to file a lawsuit/appeal/recourse at any stage and level before the competent administrative court.
What benefits does this law provide?
1.Cancellation of unpaid liabilities (up to 31.12.2014):
-Tax liabilities (excluding social and health insurance contributions);
-Liabilities under Law No. 9632/2006 “On the Local Tax System”;
-Administrative penalties (fines and late-payment interest) related to social and health insurance;
-Liabilities imposed on deregistered entities after the date of deregistration at the National Business Center (QKB).
2.Partial extinguishment of liabilities subject to payment of tax/duty/fee/contribution:
-For tax liabilities and local taxes/fees for the period 1 January 2015 – 31 December 2019 (excluding social and health insurance contributions):
a) 50% extinguishment, if the remaining 50% is paid by 30.06.2026;
b) 25% extinguishment, if the remaining 75% is paid by 31.12.2026.
In the above cases, fines and late-payment interest for the respective periods are fully cancelled.
-Fines and late-payment interest for the period 1 January 2020 – 31 December 2024 are cancelled, provided the respective tax/duty/fee is fully paid by 31.12.2026;
-Administrative penalties (fines and interest) related to social and health insurance for the period 1 January 2015 – 31 December 2024 are cancelled, provided 100% of the contribution is paid by 31.12.2026;
3. Cancellation/extinguishment of other tax liabilities:
-Tax/duty/fee/interest/administrative penalties for taxpayers deregistered by the National Business Center (QKB), court decision, or tax administration up to 31.12.2024;
-Administrative penalties for late filing up to 31.12.2024, including penalties related to employee declaration deadlines;
-Administrative penalties (fines) for failure to submit tax returns for periods up to 31.12.2024, provided all outstanding returns are submitted by 30.06.2026;
-Administrative penalties (fines) for late submission of decisions on profit allocation and late submission of filed financial statements, calculated up to 31.12.2024;
-Fines and interest generated in the system due to amendments in payroll declarations for past periods, resulting from the implementation of a law or sub-legal act with retroactive effect or the enforcement of a final court decision.
4. Cancellation of liabilities payable to customs:
-Full cancellation:
a) Customs liabilities up to 31.12.2014;
b) Fines/late-payment interest for debtor entities for these periods only.
-Conditional extinguishment (1 January 2015 – 31 December 2019):
a) 50% extinguishment if 50% is paid by 30.06.2026;
b) 25% extinguishment if 75% is paid by 31.12.2026.
– Fines and late-payment interest for the period 1 January 2020 – 31 December 2024 are waived, provided full payment of the principal is made by 31.12.2026.
– Liabilities up to ALL 1,500 for entities with no other outstanding obligations.
– Liabilities of individual debtors for whom there is no identification number (ID), no notification due to lack of identification, and no enforced debt recovery decision, including individuals who cleared vehicles through customs using the general NIPT/NUIS A000000A.
Important! For all the above liabilities, if the principal amount has already been paid and only fines and late-payment interest remain outstanding in the taxpayer’s account, such fines and interest are fully cancelled.
What can we do for you?
If you wish to benefit from this law and be part of the cancellation/extinguishment scheme, we are available to assist you throughout all stages of the process.
