AADE issues circular E.2094 detailing obligations under the Digital Transaction Fee, which replaces the historical stamp duty system from 1 December 2024.
Greece’s Independent Authority for Public Revenue (AADE) has issued Circular E. 2094/2025 on 6 November 2025, clarifying the application of the country’s new Digital Transaction Fee, which replaces the historical stamp duty system.
The Circular provides guidance for individuals, businesses, legal entities, and government bodies on their obligations under the Fee, introduced by Law 5177/2025.
End of Stamp Duty and Digital Modernisation
The Digital Transaction Fee, effective from 1 December 2024, marks the definitive end of the stamp duty system and the associated special social contribution for the O.G.A. The Fee is collected digitally and applies to transactions regardless of whether they are conducted on paper or electronically. Proof of transactions can include agreements, receipts, accounting entries, judicial drafts, and bank records.
The Fee can take a proportional form (a percentage of the transaction value) or a fixed amount for certain administrative actions, such as issuing passports or professional licences. The new system also removes territorial limits, meaning the Fee applies regardless of where documents are signed.
Key Provisions for Financial Transactions
- Loans and Credit: The Fee applies to loans, credit limits, and credit cards. Business-related loans generally carry a 2.40% fee, while other loans, including between private individuals, are charged at 3.60%. The maximum fee per loan is EUR 150,000, with open credit agreements treated as separate loans for each drawdown.
- Interest: Conventional interest is exempt from the fee, while penalty and legal interest are subject to a 3.60% rate.
- Exemptions: Certain transactions, including donations, inheritance-related transfers, VAT-subject contracts, and specific administrative acts, are exempt. Residential leases, storage, parking spaces linked to housing, and employee housing provided by companies are also excluded.
Real Estate and Commercial Leases
Commercial property leases are subject to a 3.60% Fee unless they opt into the VAT regime. Residential leases remain exempt.
Transition and Foreign Contracts
Transactions up to 30 November 2024 remain under the old stamp duty. Foreign contracts involving Greek residents or permanent establishments executed materially after 1 December 2024 are subject to the fee. AADE warns that using the old stamp duty form for post-December transactions will not be legally valid.
The circular provides essential guidance for taxpayers and administrators as Greece fully transitions to its new digital taxation system.
