Contract analysis

I. Identification of Parties and Representation We write on behalf of our client, Thalassa Shipping & Logistics Société Anonyme ("TSL"), a company duly organized and existing under the laws of the Hellenic Republic, with its registered office at 47 Akti Miaouli, 185 35 Piraeus, Greece (EORI: GR094827361000; AFM: 094827361), in connection with the above-referenced dispute concerning two Additional Duty Assessment Noti

II. Background of the Assessment Notices On August 12, 2022, the Piraeus Regional Customs Office of AADE, located at 2 Karaoli & Dimitriou Street, 185 31 Piraeus, Greece, issued two Additional Duty Assessment Notices to TSL in connection with the post-clearance audit conducted under file reference AADE/DTE/2022/PIR-04518. The audit concerned the importation by TSL, during the period between January 2020 and September

III. Administrative Objections Filed On November 30, 2022, TSL, through V&T, filed formal administrative objections to both Assessment Notices before AADE's Directorate of Resolution of Disputes ("DED"), pursuant to Article 44 of Regulation (EU) No. 952/2013 (Union Customs Code) and Article 63 of Law 4174/2013 (Greek Tax Procedure Code). The administrative objections, which were filed within the applicable statutory

IV. BTI Application and DG TAXUD Referral On November 15, 2022, TSL filed a Binding Tariff Information ("BTI") application with AADE under Article 33 of the Union Customs Code, requesting a formal ruling that the twelve (12) STS gantry cranes and the eight (8) ASC systems imported by TSL are properly classified under CN code 8426 19 00, within heading 8426 of the Combined Nomenclature. The BTI application was assigne

V. Rationale for Standstill In light of the foregoing, and in particular the pending DG TAXUD consultation on the classification of STS gantry cranes and ASC systems, which, based on our experience with similar referrals, may take between twelve (12) and twenty-four (24) months to be resolved, TSL respectfully proposes that the parties enter into a standstill arrangement on the terms set forth below. TSL submits that

VI. Proposed Standstill Terms TSL proposes that the standstill arrangement be governed by the following terms: Term 1: Enforcement Standstill AADE shall not enforce, seek to collect, or take any coercive or compulsory collection measures with respect to the amounts assessed under Assessment Notices AADE/ADAN/2022/0073 and AADE/ADAN/2022/0074 during the standstill period. For the avoidance of doubt, this includes, wit

VII. Closing V&T, on behalf of TSL, believes that the standstill arrangement proposed herein serves the legitimate interests of both parties by avoiding unnecessary enforcement proceedings, the commencement of administrative court litigation, and the associated costs and administrative burden, while the core classification question is resolved through the appropriate EU-level mechanism — namely, the DG TAXUD consulta