AADE has introduced a Tax Rulings procedure under which businesses and individuals can obtain, in advance, its interpretation of tax and customs legislation on specific future acts or transactions. The procedure entered into force on 1 October 2026.
The Independent Authority for Public Revenue (AADE) of Greece has introduced a new Tax Rulings (TR) procedure. It allows businesses and individuals to know in advance how the authority interprets tax and customs legislation in relation to specific future acts or transactions.
The details and conditions for the issuance and application of Tax Rulings are set out in a Decision (A.1204/2026) of the AADE Governor, Giorgos Pitsilis. The procedure entered into force on 1 October 2026.
Scope
A Tax Ruling gives AADE’s interpretative position in advance on specific and sufficiently defined circumstances relating to future acts or transactions. A prerequisite is the existence of a specific interpretative issue concerning the application of tax or customs legislation. Among other matters, a Tax Ruling may also concern the application of the general anti-avoidance rule, as well as anti-abuse clauses in Double Taxation Agreements.
No Tax Ruling will be issued for:
- matters concerning advance pricing agreements for transfer pricing methodology;
- issues concerning the application of foreign law in Greece;
- issues relating to the applicant’s cases where an administrative appeal is pending before the Dispute Resolution Directorate or where legal proceedings are pending;
- issues concerning binding customs decisions;
- questions seeking general guidance without specific circumstances; and
- purely hypothetical or abusive questions.
Submission and fee
Until the dedicated application becomes operational, applications and the relevant supporting documents must be submitted by email to [email protected].
A fee is required for the submission and examination of an application. It ranges from EUR 10,000 to EUR 50,000, depending on the number and complexity of the issues for which the Tax Ruling is requested, the legal form of the person submitting the question and any request for expedited processing.
Timeline
The Tax Ruling is issued by the AADE Governor, following a recommendation from the competent service, within 150 days of receipt of the complete application and payment of the total fee. Where expedited processing is requested and the corresponding increased fee is paid, 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 through to the issuance of the Tax Ruling or rejection of the request. The applicant can also monitor the progress of the application at any time.
Validity and binding effect
A Tax Ruling is binding on the Tax Administration in relation to the person for whom it was issued and on the basis of the specific circumstances examined. Its binding effect also extends to third parties in relation to identical circumstances occurring after publication of the Tax Ruling and under the same legal framework.
By contrast, a Tax Ruling does not bind the taxpayer, who is not required to follow the interpretation provided. However, if the taxpayer follows a Tax Ruling that is in force, their tax return will not be considered inaccurate or, as applicable, as not having been submitted, in respect of the specific tax obligation. The same protection applies to the period during which the Tax Ruling was in force, even if it subsequently ceased to apply.
A Tax Ruling cannot be challenged through an administrative appeal or legal proceedings. Its validity ceases, among other circumstances, in the event of a material change in the facts or the relevant legislation, as well as where a higher court reaches a contrary interpretative decision.
Publication
For reasons of transparency and the uniform application of tax and customs legislation, Tax Rulings are published on the AADE website in anonymised or pseudonymised form within 60 days of being notified to the applicant.
Following a reasoned request, publication may be postponed until the circumstances under examination occur and, in any event, for up to 12 months, where there is a risk of disclosure of a planned transaction. The applicant may also request that information concerning trade, business, industrial or professional secrets, or a commercial process, not be published.
The new procedure is now in force, with applications to be submitted by email until the dedicated application becomes operational.
This announcement was made on 2 October 2026.
