The Ministry of Finance published today guidelines on the application of Article 12 of Law 3943/2012 on the definition of 'tax residence" and the rules on the change of tax residence (Circular 1142/2012).
The circular with the guidelines comes with a 14-month delay (the provisions it deals with were approved by the Parliament in March 2011) and it is very much welcome. It provides insight on the approach the Ministry is going to take in the application of the relevant provisions but it does not solve any of the hermeneutical or practical problems that have been identified by practitioners.
The circular with the guidelines comes with a 14-month delay (the provisions it deals with were approved by the Parliament in March 2011) and it is very much welcome. It provides insight on the approach the Ministry is going to take in the application of the relevant provisions but it does not solve any of the hermeneutical or practical problems that have been identified by practitioners.
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