Tax Updates: September 6th 2024

The Greek Ministry of Finance and the Independent Authority for Public Revenue (“IAPR”) recently issued the Decisions A. 1122/2024 and Α. 1123/2024 for the implementation of electronic delivery notes and digital tracking of goods shipment.

Decision A. 1122/2024 outlines the extent of application, exceptions and transmission timeframe of the relevant obligations, and stipulates the implementation of the electronic delivery note, divided in two (2) phases as follows:

Phase I involves the issuance of e-delivery documents, the transmission of data to the myDATA platform through the notification of the delivery recipient, as well as the digital monitoring of the shipment through the scanning of the 2-dimensional bar code (QR code). More specifically:

The issuer of the electronic delivery note shall transmit in real time the data of the delivery or receipt of the goods. In the event of quantity differences in warehouse incoming loads (surplus or deficit), such differences shall be reportable within fifteen (15) days from the day of the goods’ movement.

• Throughout delivery, the origin/details of the transaction can be verified by scanning the 
• QR code located on each domestic shipping document.
• In case of purchases from foreign vendors, the recipient of the delivery document shall transmit the relevant data by the twentieth (20th) day of the month following the issuance date of the purchase invoice or the goods receipt document. 

Businesses with FY2022 gross revenues exceeding EUR 200 000, based on their submitted corporate income tax return for FY2022, or mainly operating in specific sectors in FY2022 based on their NACE Codes (i.e. fueling/energy, pharmaceutical, medical consumables, construction materials, olive oil production, etc.) are required to comply with the above requirements by 

1 December 2024. The decision lists exemptions granted to certain groups of businesses and types of transactions. As of 1 April 2025, the above requirements are extended to all remaining businesses, except for public entities and other legal persons governed by public law, which must comply by 1 January 2026.

Phase II becomes mandatory as of 1 April 2025 and deals with the digital monitoring of the shipment, the reporting of the goods’ receipt through the scanning of the QR code located on each domestic shipping document, en route transloading, as well as the quantitative and qualitative control by the recipient. Moreover, the transmission of the nomenclature of the goods transported, as described in the EU Customs Tariff, becomes mandatory.

Decision A. 1123/2024 mainly focuses on the technical specifications, setting a standard uniform reporting format. The decisions also list the acceptable transmission channels to report the above transactions in the myDATA platform (i.e. ERP middleware, e-invoicing service providers, free online invoicing platform made available by the Greek tax administration titled “timologio”).

In case of non-compliance, article 58 of Law 5104/2024 provides that failing to transmit the data of the electronic delivery notes to the myDATA platform triggers a penalty of EUR 100 per record, capped at EUR 500 per day and at EUR 20 000 per calendar year. In case of belated transmissions, the above penalties are reduced by 50%, whereas if the same violation occurs within a 5-year period, starting from each penalty assessment, such penalties are doubled and for each new non-compliance incident quadrupled, up to the limit of EUR 20 000. Τhe provisions for the penalties will enter into force only after the Tax Administration issues a relevant decision determining in detail the relevant application requirements.