Greece: New binding tax rulings regime
Taxpayers can now request advance interpretations of tax and customs legislation.
New Law 5301/2026 has introduced the framework for “binding tax rulings” in Greek legislation for the first time, following the model of other EU member states.
The binding tax rulings regime is established by adding Article 9A to the Code of Tax Procedures (Law 5104/2024). Taxpayers, whether individuals or legal entities, can now apply to the tax administration for a binding tax ruling, which provides an advance interpretation of tax and customs legislation based on specific factual circumstances that have not yet occurred. The issuance of a ruling requires interpretative ambiguity in the applicable provisions.
Important elements of the regime include:
- Binding tax rulings are issued by the Governor of the Independent Authority for Public Revenues (AADE) and are binding on the tax administration but not on the taxpayer. Taxpayers are not required to follow the ruling and cannot challenge it through administrative appeal or other legal remedies.
- The validity of a binding tax ruling lasts as long as the relevant factual circumstances and legislative framework remain unchanged, and all terms and conditions are complied with. If the ruling ceases to be valid due to changes, tax returns filed based on the ruling are not considered inaccurate for the period it was in force.
- Applications require a minimum filing fee of €3,500. The total fee ranges from €10,000 to €50,000, depending on complexity, number of issues, business size, legal form, and whether expedited processing is requested.
- The tax administration must issue the ruling or notify the applicant of rejection within 150 days of receiving the application, supporting documents, and payment. If rejected, any fee paid above the minimum €3,500 is refunded.
- Matters excluded from the scope include prior approval of transfer pricing methodologies, implementation of foreign law in Greece, and cases when an administrative appeal or legal remedy has already been initiated.
- Binding tax rulings will be published anonymously or pseudonymously on the AADE website, with the option for applicants to request non-disclosure of trade or business secrets.
Read a May 2026 report prepared by the KPMG member firm in Greece