On 2 October 2026, the Independent Authority for Public Revenue (AADE) published a comprehensive circular detailing the procedure for obtaining Binding Tax Rulings (Φορολογικές Δεσμευτικές Απαντήσεις – ΦΔΑ). The guidance covers application content, required supporting documents, processing timelines, and the legal force of issued rulings under the Tax Procedure Code (Law 4174/2013). It aims to enhance legal certainty for taxpayers engaging in complex transactions.
Key Takeaways
- Streamlined Application Process: The circular introduces a standardized electronic submission form via the AADE portal, reducing processing time to 60 days for standard cases.
- Scope Expansion: FDAs now explicitly cover cross‑border transactions, transfer pricing, and digital services taxation, aligning with BEPS Action 12 and EU DAC6.
- Legal Effect & Revocation: Issued rulings bind the tax administration for the specific taxpayer and transaction; they can be revoked only if based on incomplete or inaccurate information.
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