Greece opens advance binding tax-ruling procedure

A new procedure under the Tax Procedure Code

Decision A.1204/2026 implements Article 9A of the Tax Procedure Code, Law 5104/2024, which was inserted by Article 36 of Law 5301/2026. Article 39 of Law 5301/2026 also added Article 83(6A), authorising the AADE governor to set the application, fee and examination procedure. The decision applies to applications submitted from 1 October 2026.^[1][2]

Future transactions and defined exclusions

An individual, legal person or entity may request AADE’s advance interpretation of Greek tax or customs law for specific, sufficiently defined facts that have not yet occurred. The procedure excludes advance pricing agreements under Article 26, the application of foreign law in Greece and issues already subject to an administrative appeal or court remedy. It also excludes the separate customs mechanisms for binding tariff, origin and valuation decisions. Questions concerning the general anti-abuse rule in Article 39 and treaty anti-abuse provisions may be submitted.^[1][2]

Application, fees and timetable

Applications use the myAADE digital channel; until the dedicated application is available, the decision permits submission to ruling@aade.gr. Foreign applicants without a Greek tax number must act through an authorised representative using TAXISnet credentials. The total fee ranges from €10,000 to €50,000, reflecting factors including the number of taxes, complexity, cross-border or multi-party features, applicant size and any expedited request. The standard decision period is 150 days after a complete application and full fee, while the expedited procedure has a 90-day target.^[1][2]

Binding effect and publication

A ruling binds the tax administration for the named taxpayer while the facts, law and stated conditions remain unchanged and no conflicting supreme-court interpretation intervenes. Once published, it also binds the administration for third parties with identical facts under the same legal framework. It does not bind the taxpayer, but following a valid ruling protects the related return from being treated as inaccurate or omitted. AADE must publish an anonymised or pseudonymised version, normally within 60 days, although publication may be deferred for up to 12 months for a planned transaction and confidential material can be withheld.^[1][2]

Practical consequence for groups

Multinational groups can now seek prospective certainty on Greek tax and customs questions outside the transfer-pricing APA route, including cross-border structures and anti-abuse interpretation. The cost and detailed-facts requirement make the procedure most useful where the exposure or implementation decision is material. Applicants should frame a genuinely future transaction, identify every relevant provision and jurisdictional element, and preserve the assumptions and conditions on which continued protection depends.^[1]