Greece's first binding tax ruling (BTR) regime, introduced by Article 36 of Law 5301/2026 (ΦΕΚ Α' 74/15.05.2026) which inserts Article 9A into the Greek Tax Procedure Code (KFD), becomes applicable on October 1, 2026. From that date, the Independent Authority for Public Revenue (AADE) can issue binding advance interpretations of Greek tax or customs legislation for transactions a taxpayer plans to undertake.
Large Greek enterprises and multinationals planning complex or cross-border transactions, and the tax advisory, law and accounting firms that prepare their filings, can file a BTR application with AADE from October 1, 2026, paying an admissibility fee of EUR 3,500 plus a total fee of EUR 10,000 to 50,000; AADE must then issue the ruling or a reasoned rejection within 150 days. Taxpayers who do not obtain a BTR forgo binding advance certainty and the protection against being treated as having filed an inaccurate or unfiled return, and retain standard audit and penalty risk under the KFD.
- Deadline : October 1, 2026, the BTR regime under Article 9A KFD becomes applicable
- Who : Any individual or legal entity planning a transaction with a genuine interpretative Greek tax or customs issue, and their advisors
- What : File a BTR application with AADE (admissibility fee EUR 3,500 plus total fee EUR 10,000 to 50,000); AADE issues the ruling or a reasoned rejection within 150 days
- Otherwise : No binding advance certainty; standard audit and penalty risk under the KFD remains
- Official source : Law 5301/2026, ΦΕΚ Α' 74/15.05.2026 (official text, PDF)
What is due on October 1, 2026
Two obligations fall due when the regime enters into force. First, any taxpayer filing a BTR application must pay an admissibility fee of EUR 3,500 and a total fee of EUR 10,000 to 50,000, set by complexity, the number of issues, the applicant's legal form and size, and any expedited-processing request, for the application to be admissible. Second, AADE must issue the binding ruling or a reasoned written rejection within 150 days of receiving a complete application, the supporting documents and the full fee; on rejection, the excess over EUR 3,500 is refunded. Law 5301/2026 was published on May 15, 2026, and Article 36 enters into force on October 1, 2026, with further procedural detail to be set by decision of the Governor of AADE.
Who is covered
The regime is open to any individual or legal entity planning a transaction where a genuine interpretative issue of Greek tax or customs legislation arises from specific, sufficiently defined facts that have not yet materialised. The exposed actors are large Greek enterprises and multinationals operating in Greece planning complex or cross-border transactions, Greek tax advisory firms (Big 4 and domestic), Greek tax law firms and in-house counsel, and Greek accounting and payroll firms advising on filings.
Excluded from the regime: advance pricing agreements under Article 26 KFD, the application of foreign law in Greece, and matters already under administrative appeal before the Dispute Resolution Directorate or under judicial review at the time of filing.
What to do before October 1, 2026
- Identify transactions in the pipeline that raise a genuine interpretative Greek tax or customs issue
- Assemble the specific, sufficiently defined facts, not yet materialised, that the BTR will address
- Budget the EUR 3,500 admissibility fee and the EUR 10,000 to 50,000 total fee set by complexity, issues, applicant size and any expedited request
- Confirm the transaction is not excluded: an Article 26 KFD advance pricing agreement, a foreign-law question, or a matter under appeal or judicial review
- Prepare the supporting documents and the full fee for a complete application
- Plan transaction timing around the 150-day AADE response window
What happens otherwise
A taxpayer who does not obtain a BTR forgoes binding advance certainty and the protection against being treated as having filed an inaccurate or unfiled return, and retains standard audit and penalty risk under the KFD. A valid BTR is binding on the tax administration but not on the taxpayer, who cannot appeal the ruling itself; it remains in force while the facts and legislation are unchanged, no Supreme Court holds a contrary interpretation, and any conditions are met. BTRs are published on the AADE website in anonymised or pseudonymised form, with a right to request non-publication of trade, business or industrial secrets. Continuous per-jurisdiction monitoring surfaces the AADE Governor's procedural decisions the moment they publish.
