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Union of Greek Certified Public Accountants (Π.Ο.Φ.Ε.Ε.): Urgent need for modification of issues arising in areas requiring correction regarding form submissions and support for significantly affected economic units not included in the relevant schemes.

Announcement by Π.Ο.Φ.Ε.Ε.
Athens, March 21, 2020

Ref. Outgoing No. 077

Subject: Participation with proposals and remarks on the Special Purpose Compensation (ΠΝΠ) and the planned electronic platform for implementing support measures for entrepreneurship and financial assistance.

Dear Ministers,

Acting directly and in order to contribute to the formation of your Ministerial Decision of article 11Ε, of Legislative Content Act (20/03/2020), so that the process provided for in the declarative obligations of employers and entitled employees, to be handled by Accountants-Tax Consultants, will be as simplified and flexible as possible (avoiding unnecessary data exchanges, etc.).

• General remarks:
  • It is emphasized that the measure must include both individual businesses and legal entities (clarification is needed).
  • In the list of businesses affected by the spread of the coronavirus and which have been suspended either due to a ban on business operations by a public authority or due to the application of the measure since they are significantly affected and may suspend employment contracts in whole or in part, all businesses should be included regardless of whether they have declared their CAE as their primary or secondary activity (as there is a mismatch between the register and the actual turnover).
• Specifically regarding the implementation:
  • The deadline of March 31 for all the steps of the implementation described in paragraph 11Γ is entirely tight because:
    • Firstly, the submission of the February payroll statement (to draw data from the “ERGANI” system) must precede.
    • Secondly, the sequence of steps provides for the declaration of suspension of activities first, then the declaration of suspension of employment relationship – responsible declaration, and then the submission of the responsible declaration in writing or electronically on the same day to the employee (also stating the protocol number of their action in the “ERGANI” system).
    • Consequently, the employees-entitled persons will then submit a responsible declaration with information (excluding those that are automatically drawn), of the bank account (IBAN), and the protocol number of the employer’s responsible declaration on the electronic platform.
  • From the above, it becomes clear that for this entire sequence of procedures, there will be cases of employers and employees who will not meet the above deadline and will be excluded from the support mechanism, which is not the intention of the Government.

In view of the above, we propose:
Not to set the deadline of March 31, 2020 as final, but to keep the implementation dynamically open within the framework of the most effective possible implementation of the measure.

Of course, as we have already mentioned, this procedure will be handled through accounting offices, which will make every effort, despite adverse conditions and significant staff shortages due to precautionary measures.

Please note that we are thoroughly studying the points for further simplification concerning the implementation of the planned application (article 11Δ platform) and for this purpose, we are willing and open to direct cooperation with Π.Ο.Φ.Ε.Ε. and potential exchange of views.

Sincerely,
The Board of Directors of Π.Ο.Φ.Ε.Ε.