Judicial Review over the Extension of the Limitation Period in Tax Cases: Hellenic Council of State (Simvoulio tis Epikratias) Judgment no. 1738/2017, in Plenum

Judicial Review over the Extension
of the Limitation Period in Tax Cases:
Hellenic Council of State (Simvoulio tis Epikratias)
Judgment no. 1738/2017, in Plenum

Eirini Spanaki

Assistant Judge, Greek Council of State

Provisions enacting the extension of the limitation period in tax cases are contrary to the paragraphs 1 and 2 of Article 78 of the Greek Constitution and to the principle of legal certainty, to the extent that their scope includes tax claims incurred in years prior to the year before the publication of the relevant laws.