Greece Tax Authority Introduces New Binding Ruling Procedure

A New Framework for Tax Certainty

The Independent Authority for Public Revenue (AADE) in Greece has launched a formal procedure for issuing binding tax and customs rulings. This framework enables taxpayers and legal entities to understand in advance how tax regulations apply to specific future transactions.

The process covers distinct interpretive questions regarding tax or customs law, including anti-avoidance provisions and double taxation treaties. However, rulings will not be issued for transfer pricing methodologies, foreign law applications, or cases with pending legal disputes.

Fees and Timelines

Submitting an application requires a fee ranging from 10,000 to 50,000 euros, calculated based on the complexity of the issues, the legal form of the applicant, and any request for expedited processing. The final ruling is issued within 150 days from receipt of a complete application, or within 90 days if an expedited option is selected.

The resulting decision binds the tax administration regarding the specific applicant and similar future cases under the same legal framework. While taxpayers are not legally forced to follow the ruling, doing so protects them from penalties and guarantees that their tax filing is recognized for the active period.

Transparency and Publication

For transparency purposes, rulings are published on the AADE website in an anonymized format within 60 days of notification. Applicants may request deferred publication up to 12 months to protect commercial secrets or upcoming transactions. Further support is available through the official digital and telephone channels of the Greek tax administration.