On 2 October 2026, AADE issued Circular 1123/2026 establishing a streamlined procedure for obtaining Binding Tax Rulings (Φορολογικές Δεσμευτικές Απαντήσεις – ΦΔΑ) under Article 38 of Law 4174/2013. The new process introduces a fully digital application via the myAADE portal, standardized response templates, and a strict 90-day statutory deadline for issuance. Applicants must now submit a structured fact pattern, legal analysis, and proposed ruling, with a non-refundable fee of €500 for individuals and €2,000 for legal entities. The ruling binds AADE for the specific transaction described, provided facts remain unchanged, and can be relied upon in subsequent audits. Importantly, the circular clarifies that rulings on anti-avoidance provisions (GAAR) will not be issued, and the procedure cannot be used for retroactive validation of completed transactions.
Key Takeaways
- Digital-First Application: All submissions must be made through the myAADE platform with qualified electronic signature; paper applications are no longer accepted.
- Fixed Timelines and Fees: The 90-day deadline starts upon acknowledgment of complete submission; fees are tiered by applicant type and complexity.
- Limited Scope and Non-Retroactivity: Rulings cover future transactions only and exclude general anti-avoidance rule (GAAR) assessments, preserving AADE’s discretion on abusive arrangements.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement