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thanks for your comments. With rgeards to the question I believe they already are. I know of people locally who are being fined now – currently the furthest back is about 3 years. What is happening (and I can only speka for here not the Country as a whole) is this. They have decided everyone who bought their home has underdeclared by 20% (probably not far off the mark) and issue fines accordingly.
If you appeal the fine then you have to prove that the price you paid was the price at the time. They will organise a catastral valuation and endeavour to determine the value of your property at the time you bought it – based on what I dont know but they will probably apply the price per sq m formula of the price at that moment in time.
If they find that your property is correctly valued and declared then they will waive the fine – however you will still have to pay for the administration of the survey, the instructing of the lawyers and the architects etc which will amount to around €1,500 so it may not be worth your while. Alternatively they may find that your house was valued much higher and slap a bigger fine on it.
If you kept all the original paperwork (the private contract, receipts for the deposit, receipts for all monies paid) then it should be even easier to prove – but not manuy I know who have (I dont think I have either).
Hope this helps