The article was drafted by Alexandra Karadima, Senior Associate & Christos Theodorou, Partner on 20 July
Introduction
Greece has taken a significant step towards modernizing its tax administration with the introduction of a formal Advance Tax Ruling (“ATR”) framework. Enacted through Article 9A of the Code of Tax Procedure by Law 5301/2026, the new regime—effective from 1 October 2026—allows taxpayers to obtain binding guidance from the Independent Authority for Public Revenue (“AADE”) on the tax consequences of contemplated transactions before they are implemented.
Advance tax rulings have long been recognized as an important feature of modern tax administrations across Europe. They provide businesses and investors with greater certainty when undertaking complex transactions, facilitate investment decisions and reduce the likelihood of future tax disputes. By introducing a structured ruling mechanism, Greece aligns itself with the practice followed in many other European jurisdictions and reinforces its broader objective of promoting transparency, predictability and cooperative compliance.
What is an Advance Tax Ruling?
An AΤR is a written interpretation issued by AADE confirming how Greek tax or customs legislation should apply to a specific transaction or arrangement before it is implemented. In this sense, the ATR provides certainty as to how the existing legislative framework should be interpreted and applied to the specific facts presented by the applicant.
The scope of the new framework is deliberately broad. Taxpayers may request rulings in relation to virtually all taxes administered under the Code of Tax Procedure, including corporate income tax, personal income tax, VAT, Digital Transaction Fee and customs matters. This makes the Greek regime one of the most comprehensive advance ruling systems currently available within the European Union.
Who Can Apply and Under What Conditions?
The new framework is designed to resolve genuine interpretative uncertainty before a transaction takes place. Accordingly, an application will generally be admissible only where:
- the transaction or arrangement has not yet been implemented;
- the relevant facts are sufficiently clear and complete to enable a legal assessment; and
- the request raises a genuine “gap” regarding the interpretation or application of Greek tax or customs legislation (meaning an issue that is not addressed by any administrative circulare).
The ruling mechanism is therefore not intended to provide abstract legal opinions or confirm the straightforward application of clear statutory provisions. Instead, it is aimed at situations where uncertainty exists and taxpayers require certainty before proceeding with a proposed transaction.
Article 9A also expressly excludes certain matters from the scope of the regime. Advance tax rulings cannot be requested for:
- transfer pricing matters already covered by the Advance Pricing Agreement (APA) framework;
- issues requiring the interpretation or application of foreign law; or
- matters that are already subject to administrative or judicial dispute resolution involving the applicant.
The Procedure
The ruling process is initiated by submitting an application to AADE together with the prescribed documentation and payment of the applicable administrative fee.
The legislation adopts a variable fee structure, ranging from EUR 3,500 to EUR 50,000, depending on factors such as the complexity of the request, the number of issues involved, the size of the applicant and whether expedited treatment is requested. Where the application is rejected within the statutory deadline, the amount exceeding the initial filing fee is refunded.
Although the level of the fees is higher than in some European jurisdictions, it reflects the highly specialised nature of the ruling process and seeks to ensure that the mechanism is used for transactions involving genuine interpretative uncertainty rather than theoretical or speculative questions.
You can read the full article here: Newsletter_Greece Introduces Advance Tax Rulings A New Era of Tax Certainty