E9 – The tax office does not forgive the mistakes of carelessness

The tax office not only does not forgive the mistakes made when filling out the E9 form, but severely punishes those who did not make these mistakes intentionally but by carelessness.

From 2014 onwards, computer applications are planned to increase the EN.F.IA. in any case where the individual data entered in E9 have the slightest error.


1. The year of birth of the usufructuary in real rights:

The year of birth of the usufructuary, according to the law, determines the ENFIA of the usufructuary and of the small owner. But it must be written correctly in E9 by both with a four-digit number. E.g. year of birth of usufructuary 1950. Must be written “1950”. If “50” is written, then ENFIA will be counted as full ownership.

Specifically: In case the type of the right in rem (fine ownership or usufruct) is not written correctly in E9, ie if the year of birth of the usufructuary for the specific right is empty, the property is considered to be fully owned by the taxpayer who made this omission and having small ownership or usufruct. This means that the small owner and the usufructuary will not “share” ENFIA. They will be charged with more EN.F.IA.

In case of real right with usufructuary legal entity, a fixed price of 0.80 will be written for usufruct

2. Co-ownership percentage: In case of non-indication or incorrect indication of co-ownership percentage, the System takes into account a co-ownership percentage of 100% (!).

3. The floor: If the property floor is not completed, the rate corresponding to the sixth floor (!) Is taken for the calculation of the tax. And the EN.F.IA is significantly increasing.

4. Geographical location of the property: If the geographical location of the plot is determined only by the prefecture, the highest Initial Basic Value (ABA) of the prefecture is taken for the main tax of natural and legal persons and, if applicable, the largest ABA or Special Basic Value (EBA) ) for the additional tax of natural and legal persons. If the geographical location of the plot is determined only by the prefecture and municipality, the largest ABA or EBA of the municipality is taken on a case by case basis for the additional tax of natural and legal persons

5.The property category for the buildings located on the plot: When the column of the total area of buildings located on the plot has been completed but the category of the property has not been completed, it is considered that there is a house (!) On the plot and more ENFIA is charged

6. The facade of the plot: If the facade details of the plot have not been filled in or have been filled in incorrectly, for the additional tax of natural and legal persons, it is considered that the plot has a facade on a national (!) Or provincial road and more ENFIA is charged

7. More than one zone on a plot: If there is more than one zone, with the same lower price, as a plot factor (S Oik.), Total starting price of the plot and plot utilization factor (S.A.O.), these are taken, from the combination of which the lowest taxable value of a plot of land results.

8. Building blocks: If the APAA maps do not show the individual building blocks for some areas, they are completed based on any appropriate means.


P.S. Our opinion is that the provisions in force from 2014 should be abolished. The tax office should notify the taxpayer electronically of the existing negligence errors in E9 and urge him to correct them and not to proceed to the above unfair, unethical and excessive burdens on citizens. (Especially now that technology allows for comfortable electronic communication between us).
No one is infallible. Not even the legislators.