Important Warnings on the Tax Authority's Scrutiny of Bank Transfers to Personal IBANs

For those selling through social media, freelancers, or anyone regularly receiving payments from different people, one topic keeps coming up more often: bank transfers to personal IBANs coming under tax authority scrutiny. This isn’t arbitrary enforcement — it’s a natural consequence of data sharing between banks and the tax administration.

Why Are Bank Transactions Reviewed?

Banks are required to share account activity above certain volume and frequency thresholds with regulatory bodies. An account receiving similar-amount payments from many different people at short intervals signals that the activity could be payment for goods or services. The tax authority uses these patterns to identify people without tax registration, or whose declared income doesn’t match their bank activity.

The Consequences of Income With No Traceable Source

When an account’s activity is reviewed and no invoice, contract or other legal basis is found for it, the following consequences can follow:

• A retroactive tax assessment with penalties: The amount identified is treated as unregistered sales income, and the tax calculated on it is demanded along with a tax loss penalty and late payment interest.
• A criminal complaint to the prosecutor’s office: If the account is found to have been used for someone else’s commercial collections, criminal proceedings can be initiated against the account holder.
• A separate assessment on commission income: The person who “let” their account be used this way can also be taxed separately on the commission income presumed to have been earned for that service.

These three outcomes show that this isn’t something you can address later with a “I’ll just pay the tax” mindset — the second and third points carry criminal and third-party liability dimensions.

The Most Common Risk Scenarios

• Selling through social media, collecting payment into a personal account, and never issuing an invoice at all.
• Running a freelance activity (consulting, design, translation) through a personal account without setting up a company or tax registration.
• Letting a friend or family member use your IBAN for their commercial collections — in this case, the account holder may have to prove the income isn’t theirs.

How Do You Protect Yourself?

The solution isn’t complicated, but it takes discipline:

1. Issue an invoice for every commercially-natured payment. A small amount doesn’t remove the invoicing obligation.
2. Separate your personal and business accounts. If you’re registered, keeping your collections in a separate account from your personal spending makes your own tracking easier and keeps your account activity legible under review.
3. Don’t let your account be used for someone else’s collections. It may look like a well-meaning favor, but it puts you at both criminal and financial risk.
4. Keep your bookkeeping current. Make sure the invoices you issue are correctly reflected in your period tax returns.

If You Don’t Have Tax Registration Yet

If you’re earning regular income but don’t yet have tax registration, the right move is to start the company registration process without delay. Setting up a sole proprietorship is typically a low-cost process completed quickly, and it stops the retroactive-review risk from this point forward. See our sole proprietorship formation guide for more on choosing a company type.

How We Support This

Keeping consistency between bank account activity and declared income is one of the core checkpoints in our monthly bookkeeping process. We review your current account structure with you and build one that’s clearly separated between commercial and personal activity — and defensible under review.