Greece Council of State ruling impacts tax statute of limitations

A ruling by the Greek Council of State (Decision 1246/2026) has declared unconstitutional provisions that extended the statute of limitations for tax evasion from five years to ten or twenty years. This decision impacts numerous tax disputes currently before the Dispute Resolution Directorate (DED) and administrative courts.

As a result, the standard five-year statute of limitations is being reinstated for many cases, significantly narrowing the window for tax authorities to impose penalties. The Independent Authority for Public Revenue (AADE) is now accelerating audits to finalize assessments before the upcoming December 31, 2026, deadline.

Tax authorities are prioritizing income tax and VAT files from the last five years, particularly from 2020, to ensure assessments are communicated before they expire. While the ruling does not automatically cancel old taxes and fines, each case will be evaluated individually based on the specific tax year and the legal provisions used to extend the previous deadlines.