The possibility for businesses, as well as citizens, to know in advance how AADE interprets tax and customs legislation, in relation to their specific future acts or transactions, is made available through the new procedure of Tax Binding Rulings (TBR).
By decision of the governor of the Independent Authority for Public Revenue, George Pitsilis, the details and conditions for the issuance and application of Tax Binding Rulings (A.1204/2026) are determined.
The new procedure came into effect from 1 October 2026.
The TBR provides in advance the interpretative position of AADE for specific and sufficiently defined circumstances concerning future acts or transactions.
A prerequisite is that there is a specific interpretative issue regarding the application of tax or customs legislation. The TBR may, among other things, also concern the application of the general anti-tax-avoidance provision, as well as anti-abuse clauses of Double Taxation Avoidance Agreements.
A TBR is not issued for:
- matters of advance approval of transfer pricing methodology,
- issues concerning the application of foreign law in Greece,
- issues concerning the applicant’s cases, for which an administrative appeal before the Directorate for Dispute Resolution or a legal remedy is pending,
- issues concerning binding customs decisions,
- questions requesting general guidance without specific circumstances,
- purely hypothetical or abusive questions.
Digital submission
Until the start of the productive operation of the special application, applications and the relevant supporting documents are submitted via email to the address [email protected].
Fee
For the submission and examination of the application, a fee is required, ranging from 10,000 to 50,000 euros, depending on the number and complexity of the issues for which the TBR is requested, the legal form of the person submitting the question, and any request for expedited response.
Issuance of response in 150 days – 90 days with expedition
The TBR is issued by the governor of AADE, following a recommendation by the competent service, within 150 days from receipt of the complete application and payment of the total fee.
In the event of a request for expedition and payment of the corresponding increased fee, the deadline is reduced to 90 days.
The applicant is informed of every stage of the procedure, from receipt of the application and any deficiencies to the issuance of the TBR or the rejection of the request, while they may monitor the progress of their application at any time.
Validity, Binding Effect and Transparency
The TBR is binding on the Tax Administration, vis-à-vis the person for whom it was issued and based on the specific circumstances that were examined.
The binding effect also extends vis-à-vis third parties for similar circumstances occurring after the publication of the TBR and under the same legal framework.
By contrast, the TBR does not bind the taxpayer, who is not obliged to follow the interpretation given.
However, if the taxpayer follows a TBR that is in force, their return is not considered inaccurate or, as the case may be, not submitted, for the specific tax obligation. The same protection also applies for the period during which the TBR was in force, even if it subsequently ceased to be in force.
The TBR cannot be challenged by administrative appeal or legal remedy.
Its validity ceases, among other things, in the event of a material change in the factual circumstances or the relevant legislation, as well as in the event of a contrary interpretative judgment by a supreme court.
Publication of TBRs
For reasons of transparency and uniform application of tax and customs legislation, TBRs are published on the AADE website, anonymized or pseudonymized, within 60 days of their notification to the applicant.
Publication may, following a reasoned request, be postponed until the occurrence of the circumstances under examination and in any case for up to 12 months, where there is a risk of disclosure of a planned transaction.
At the same time, the applicant may request that information concerning commercial, business, industrial or professional secrets or commercial process not be published.
Communication – Support
For more information, interested parties may contact AADE Taxpayer Service, my1521:
- By phone: At 1521, free of charge, on working days from 7:00 to 20:00
- Digitally: At my1521 (24/7), by selecting the topic that interests them.