Greece’s tax authority AADE has set a new procedure for binding tax rulings on planned transactions, with fees from €10,000 to €50,000. AADE announced the change on 2 October 2026.
The rules are in decision A.1204/2026, signed by AADE governor Georgios Pitsilis and in force from 1 October 2026.
What a binding ruling covers
Businesses and individuals can ask AADE in advance how it will apply tax and customs law to specific, clearly defined future acts or transactions. The procedure also covers the general anti-abuse rule and anti-abuse clauses in tax treaties.
Some requests are excluded. These include transfer pricing pre-clearances, questions on foreign law, matters already in dispute and hypothetical questions. The decision does not single out property, but its scope covers defined future transactions.
Fees and timelines
- Fee: €10,000 to €50,000, depending on the complexity of the issue, the type of applicant and whether a faster review is requested.
- Standard review: 150 days from receipt of a complete application.
- Faster review: 90 days, for an extra fee.
Until a dedicated online platform opens, applications go by email to ruling@aade.gr.
How binding is it
A ruling binds AADE towards the applicant, and towards third parties in similar circumstances that arise after it is published. The taxpayer is not obliged to follow it, but doing so protects against audit penalties.
Rulings are published on AADE’s website without names within 60 days. Publication can be delayed for up to 12 months where competition concerns arise.
What it means for buyers
Investors planning a large or unusual property transaction now have a defined route to get AADE’s view in writing before they sign. The fee level means the procedure is mainly relevant to high-value deals. Published rulings may also show how AADE treats similar cases. Buyers should confirm how this applies to them with a Greek lawyer or accountant.
What happens next
AADE plans a dedicated platform for applications; no launch date has been announced.
