Uncertainties on the status of the subject registered by the QKB as "suspended", due to failure to register the beneficial owner

Failure by reporting entities to comply with the legal obligation to initially register the data for beneficial owners or to update it whenever changes to such data occur will result in consequences, not only financial ones resulting from fines, but also related to the status of their activity on the procedure followed by the QKB. In the event of failure to comply with the above obligation, the QKB and the authority responsible for maintaining the Register of Non-Profit Organizations for reporting entities will change the status for such entities from “active” to “suspended” on the Commercial Register and the Register of Non-Profit Organizations, until the fine is paid and the data for beneficial owners is registered. Please note that from practice it appears that the QKB does not make a preliminary notification regarding the amount of the fine and subsequently the modification and change of the status of the reporting entity to suspended, but on the contrary the latter can only become aware of it on its own initiative from the note on the Chamber of Commerce certificate. Even the notification term, in case the subject intends to challenge this passage/note/decision of the QKB, starts from the moment of registration of the note at the QKB. From this procedure followed by the QKB it is uncertain, since neither Law 9901/2008 nor Law no. 9723/2007 do not provide for the "suspended status", what will be meant by the "suspended" status of the subject or whether this change of status will have consequences for the reporting subject as a taxpayer also in the tax administration.