AADE introduces new Tax Binding Answer procedure in Greece

The Independent Authority for Public Revenue (AADE) has introduced a new procedure for Tax Binding Answers (FDA), effective October 1, 2026. This mechanism allows businesses and citizens to receive advance interpretations of tax and customs legislation regarding specific future transactions or acts.

Decided by AADE Governor Giorgos Pitsilis, the FDA provides a binding interpretative position for well-defined cases. This can include matters related to anti-tax avoidance provisions and anti-abuse clauses in Double Taxation Avoidance Agreements. However, the procedure excludes certain topics, such as transfer pricing methodology pre-approvals, matters involving foreign law application in Greece, and hypothetical or abusive inquiries.

To apply, a fee ranging from €10,000 to €50,000 is required, depending on the complexity and the legal form of the applicant. Once submitted, a response is typically issued within 150 days, or 90 days if an expedited request is made. Until a dedicated digital application is operational, requests must be submitted via email.