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What is the relevant legislation relating to tax administration and controversies? Other than legislation, are there other binding rules for taxpayers and the tax authority?
The applicable legislation relating specifically to tax administration is the Code of Tax Procedure (L 4174/2013), which regulates, among other matters, the process of tax audits and controversies up to the stage of recourse to Greek courts, and the Code of Administrative Procedure (L 2690/1999), which is in general applicable to the relations of citizens and any public law entity.
Moreover, the Independent Authority for Public Revenues issues circulars that are binding on the tax authority for the interpretation and implementation of tax legislation. However, these regulations are not binding on taxpayers.
Greece has signed bilateral treaties for the avoidance of double taxation with a long list of countries in the areas of both income tax and inheritance tax.
What is the relevant tax authority and how is it organised?
Every tax authority falls under the jurisdiction of the Independent Authority for Public Revenues, which as of 2017 became an independent authority, released from state control and monitoring. The Authority is governed by the administrative council, a governor and a European Commission expert. The European Commission has appointed two officials in the council.
The competent tax office is determined by the registered seat of the legal entity or the residence of the taxpayer. The three major cities (Athens, Piraeus and Thessaloniki) have separate tax offices for limited liability corporations. For individuals who have their residence abroad, the competent tax office is determined by the residence of their tax representative. For non-Greek tax residents with an obligation to be registered in Greece, the Tax Office of non-Greek Residents (residents abroad) is competent.
For large enterprises and for individuals of a certain wealth, audit authority has been granted to specific audit centres in Athens and Thessaloniki.
Compliance with tax laws
How does the tax authority verify compliance with the tax laws and ensure timely payment of taxes? What is the typical procedure for the tax authority to review a tax return and how long does the review last?
Normally, on submission of a tax return, tax is assessed without further action by the tax authorities, either simultaneously with the submission of the tax return or shortly after in the case of annual income tax returns. However, following a tax audit, the tax authorities may issue a corrective tax assessment, provided that the audit shows that the previously submitted tax return was inaccurate or mistaken.
If the taxpayer does not file a tax return despite his or her respective obligation, an estimated tax assessment may be issued unless the taxpayer files a late tax return.
In extremely urgent cases, such as when there are indications that the taxpayer intends to leave the country, thus jeopardising the collection of taxes due, especially through the transfer of assets, the tax authorities may issue a preventative tax assessment prior to the date for submission of the respective tax return. In such a case, the taxpayer either pays the tax indicated on the preventative tax assessment as a lump sum, or secures its payment by providing a guarantee or by accepting of a lien of property in favour of the tax administration for the total amount of the tax liability.
Types of taxpayer
Are different types of taxpayers subjected to different reporting requirements? Can they be subjected to different types of review?
Different types of taxpayers are subject to different reporting requirements. Employees and pensioners are subject to limited reporting and essentially to an annual income tax return. Such individuals are usually subject to an audit if an unjustified increase in their assets is found (usually following an audit of their bank accounts). Individuals of a certain wealth are audited by a special audit centre.
Businesses (either individuals or legal entities) are subject to increased reporting standards, which involve maintaining accounting books on the basis of the simplified or double-entry accounting principle. Although efforts have been made to reduce the amount of reporting required, Greece is still a country of complicated and intensive requirements. Businesses are also subject to a variety of tax reviews, including, for example, full audit, partial audit (for a certain tax item), audit for VAT refund and audit for the issuance of fictitious invoices.
What types of information may the tax authority request from taxpayers? Can the tax authority interview the taxpayer or the taxpayer’s employees? If so, are there any restrictions?
Upon written request of the tax authorities, the taxpayer is obliged to provide copies of its books and records or any other related document for the determination of the tax liability of the taxpayer, including customers’ and suppliers’ lists, as well as any other information, within five business days from the notification of the request. There is also an obligation for certain third parties (banks, undertakings for collective investment in transferable securities, notaries, etc) to provide the tax authorities with all the requested information they possess in relation to the taxpayer within 10 days, with the exception of privileged information and documents. In the case of data and information in a foreign language, an official translation of them in Greek should be submitted.
Interviews with the taxpayer or the taxpayer’s employees are not required by Greek tax legislation. However, in practice, during a tax audit, the auditors may discuss issues raised by the audit with the taxpayer. Additionally, before notification of the final assessment, the tax audit authority is obligated to inform the taxpayer of its preliminary findings and request the taxpayer’s position.
Available agency action
What actions may the agencies take if the taxpayer does not provide the required information?
Failure to respond to requests by the tax administration to provide the required information constitutes a procedural infringement and a penalty is imposed on the taxpayer. Moreover, if the information not provided refers to the business books and records kept and issued by the taxpayer, the tax authorities may use indirect methods to determine the taxable income by calculating the taxpayer’s gross income and outflows on the basis of generally accepted principles and techniques of auditing.
Protecting commercial information
How may taxpayers protect commercial information, including business secrets or professional advice, from disclosure? Is the tax authority subject to any restrictions concerning what it can do with the information disclosed?
Data concerning third parties in their transactions with taxpayers are not covered by professional secrecy and therefore there is an obligation to provide such data. However, professional secrecy may be lifted if written permission from the competent prosecutor for the granting of data covered by such secrecy is provided.
Employees of the tax administration are obliged to keep confidential all of the taxpayer’s data and information that they receive during the exercise of their duties (duty of confidentiality). If they fail to do so, they are personally liable (for both civil and criminal purposes).
Pursuant to a recent amendment in tax legislation, in the case of outstanding debts of more than €150,000, the name of the taxpayer may be published without the taxpayer’s consent.
Limitation period for reviews
What limitation period applies to the review of tax returns?
As of 1 January 2014, the tax assessment may be issued within five years from the end of the tax year and may be extended under certain conditions, which were recently defined by the Greek Administrative Supreme Court. For tax evasion cases, the tax assessment may be issued within 20 years from the end of the tax year. However, since tax evasion may include the inaccurate submission of a tax return aimed at tax avoidance, the 20-year statute of limitation will be considered as the general rule.
Alternative dispute resolution
Describe any alternative dispute resolution (ADR) or settlement options available?
As of 1 January 2014, an administrative appeal is provided as an extrajudicial mandatory remedy for challenging any act or omission of the tax authority (administrative appeal is a precondition for the admissibility of the judicial appeal lodged before the competent administrative court). Thus, prior to any judicial review, a re-examination of the disputed act or omission is conducted by a special administrative authority particularly formed for this purpose: the Dispute Resolution Directorate (DRD) (see question 25).
Collecting overdue payments
How may the tax authority collect overdue tax payments following a tax review?
As soon as the assessment is notified to the taxpayer, the tax administration issues the taxpayer with a payment notice prior to proceeding to any enforcement action. In the event of non-payment of the amount due within 30 days from the notification of the payment notice, the tax authorities may proceed (without a judicial decision) to the imposition of a seizure of movable assets, real estate, property rights, claims and, in general, all of the debtor’s assets or, in case of the debtor being a legal entity, to all of the directors’ assets bearing joint liability (the latter is applicable under conditions specified by the law). On the basis of the above conditions, the tax authorities may also proceed to take appropriate interim measures.
It should be noted that the non-payment of tax due for a period of time longer than four months is a criminal offence (misdemeanour).
In what circumstances may the tax authority impose penalties?
The tax authority may impose penalties in cases of infringement of Greek tax legislation. These penalties distinguish between penalties for procedural infringements and penalties for infringements found following an audit by the tax authority.
Procedural infringements include (indicatively):
- non-submission or late submission of a statement of informative character or a tax return or a withholding tax return;
- non-compliance with a request of the tax administration for the provision of information or data;
- non-cooperation during a tax audit;
- non-notification to the tax administration of the appointment of a tax representative;
- non-registration before the tax registry; and
- non-compliance with an obligation regarding the keeping of books and issuance of records according to Greek accounting standards, among others.
Infringements found following an audit by the tax authority include (indicatively):
- filing of an inaccurate tax return;
- non-filing of a tax return;
- non-payment of VAT;
- non-issuance of a tax record for a transaction subject to VAT;
- issuance of false tax records;
- issuance and receipt of fictitious tax records; and
- falsification of tax records, among others.
There are also special penalties for infringements of transfer pricing legislation.
How are penalties calculated?
Penalties for procedural infringements are fixed and depend on the simplified or complex accounting status of the taxpayers; that is, different penalties are imposed on taxpayers who are not liable to maintain accounting books and those liable to maintaining accounting books on the basis of simplified or double-entry accounting principles. Repetition of any infringement within five years results in the imposition of a double penalty, whereas a quadruple penalty is imposed for a second repetition.
Penalties for infringements found following an audit by the tax authority depend on the amount of the discrepancy and are calculated as a percentage of the value of the infringement, depending on whether it concerns the fictitiousness, forgery and concealment of taxable income or the non-payment of taxes or the fraudulent refund of taxes.
Penalties for infringements of transfer pricing legislation are calculated as a percentage on the declared gross profits.
What defences are available if penalties are imposed?
The taxpayer may raise all arguments regarding flaws in the formal process of the act of assessment (eg, violations of procedure or a lack of competence), as well as disputing the basis or reasoning of the assessment. Force majeure arguments are extremely difficult to prove and reliance on the advice of an attorney or accountant is disallowed.
By virtue of a recent amendment to the law, no penalties may be imposed on taxpayers if they acted following written instructions from the tax administration.
In what circumstances may the tax authority collect interest and how is it calculated?
In cases of late payment or non-payment of any amount of tax (the latter being found following a tax review), the taxpayer is obliged to pay interest for the period from the end of the legal deadline until the date of payment of the tax. The determination of the interest rate is a decision made by the Deputy Minister of Finance. The interest rate, according to the ministerial decision currently in force, is set at 8.76 per cent. However, up until 31 December 2017, interest was calculated on a monthly basis, whereas since 1 January 2018, it has been calculated on a daily basis.
The significance of this differentiation lies in the fact that if a debt is paid on the 15th day of the month, according to the calculation currently in force, the taxpayer will be called upon to pay interest for the entire month. In contrast, from 1 January 2019, the same taxpayer will be called upon to pay 15/365 of the relevant interest (which corresponds to the 15 days that the payment was delayed).
Are there criminal consequences that can arise as a result of a tax review? Are these different for different types of taxpayers?
Legal provisions governing criminal tax evasion have been incorporated in the Greek Code of Tax Procedures, pursuant to which tax evasion is considered to be committed by persons who:
- intentionally avoids the payment of taxes (eg, income tax, uniform tax on the acquisition of ownership, special real estate tax, VAT, turnover tax, premium tax, withholding and imputable taxes, fees or contributions, shipping tax, etc) by not paying or paying incorrectly or reimbursing or setting off or deducting or withholding taxes; and
- intentionally issues false or fictitious tax records as well as receives fictitious tax records or alters such records, irrespective of whether they evade paying taxes or not.
Under the Greek penal system, legal entities do not bear criminal liability. For this reason, individuals who are engaged with the effective management, administration and representation of a legal entity (either by holding specific executive positions or by exercising de facto management duties) are considered instead as the perpetrators or accomplices of tax evasion.
What is the recent enforcement record of the authorities?
Uncollected taxes due reached about €2.5 billion by the end of 2017. The Independent Authority for Public Revenues is said to have collected €4.8 billion in 2017 from new and old debt.
Third parties and other authorities
Cooperation with other authorities
Can a tax authority involve or investigate third parties as part of the authority’s review of a taxpayer’s returns?
The tax authority has the right to request any kind of information from third parties such as other public entities (authorities, organisations or companies owned by the state), judicial or prosecution authorities or other third parties, such as financial institutions, investment funds, chambers of commerce, notaries, registrars, heads of land registry offices, economic or social or professional associations or organisations. The right is restricted for pending criminal cases or investigations where the granting of a relevant permission by the court or the prosecutor is required in order to request the information.
Third parties bound by professional confidentiality (including lawyers) may provide information related to their economic transactions with the taxpayer. However, for the rest of the information covered by the confidentiality obligation, the tax authority should request permission from the competent prosecutor on proving that the taxpayer is suspected of tax evasion and invoking the reasons for which it wishes to obtain the information by the third party.
A fine ranging from €100 to €500 will be imposed if third parties refuse to provide the above-mentioned information to the tax authority.
Does the tax authority cooperate with other authorities within the country? Does the tax authority cooperate with the tax authorities in other countries?
The tax authority may cooperate with every authority within the country.
As to tax authorities in other countries, Greece has adopted EU Directive 2011/16/EU on administrative cooperation in the field of taxation, by which every member state’s authority may request information from other member states.
Greece has also signed and applies the Convention on Mutual Administrative Assistance in Tax Matters, which was developed jointly by the Council of Europe and the OECD and promotes international cooperation in the assessment and collection of taxes.
Furthermore, Greece has adopted the Automatic Exchange of Information tax standard, developed by the OECD, under which jurisdictions obtain financial information from their financial institutions and automatically exchange that information with other jurisdictions on an annual basis. The Automatic Exchange of Information tax standard came into effect in September 2017.
In January 2017, Greece and the United States signed an intergovernmental agreement to facilitate compliance with the US Foreign Account Tax Compliance Act by financial institutions in Greece.
Voluntary disclosure and amnesties
Do any special procedures apply in cases of financial or other hardship, for example when a taxpayer is bankrupt?
If a taxpayer is declared bankrupt, the Greek state enjoys a priority right after the claims of secured creditors for claims of VAT, including any kind of surcharges thereof, and it ranks fifth after other priority creditors.
Concerning the declared bankrupt, if the Greek state has announced its claims within the bankruptcy procedure, it may request a settlement to be granted by the Minister of Finance. If the debt exceeds €600,000 the State Legal Council may accept a settlement that may involve:
- the payment of the total amount of debt along with the partial or total release from late payment surcharges, tax surcharges and fines;
- the payment of the basic debt and the late payment surcharges in monthly instalments (up to 90); or
- a combination of the previous two.
Are there any voluntary disclosure or amnesty programmes?
Since December 2016, there has been an ongoing voluntary disclosure programme of undeclared taxable income, which was effective until 20 November 2017.
Since January 2018, a possibility of the submission of a late (initial or amending) tax return following the issuance of a tax audit order was introduced. In the case of the submission of a tax return following the notification of the tax audit order and until the notification of the preliminary corrective tax assessment act, the penalties can reach up to 50 per cent of the tax due, as the case may be.
In such a case, however, on the condition that the taxpayer proceeds with payment of the tax within 30 days, the respective penalty (and not the interest for late payment) is reduced to 60 per cent.
The above reduction is not possible in certain cases specified in the law (eg, submission of late employment withholding tax returns).
Furthermore, the penalties are also reduced to 60 per cent where the taxpayer consents by means of an irrevocable and unconditional statement to the final corrective tax assessment act and further proceeds with payment of the respective penalties within 30 days.
Rights of taxpayers
Rules protecting taxpayers
What rules are in place to protect taxpayers?
The aforementioned Code of Tax Procedure and the Code of Administrative Procedure protect taxpayers, as well as the general principles of the Greek Constitution.
How can taxpayers obtain information from the tax authority? What information can taxpayers request?
Taxpayers may file a petition to the tax authority in order to receive copies of any public or private document within 20 days provided that they prove a legitimate interest. In practice, the period of reaction on behalf of the authorities may be longer and the legitimate interest may not be accepted. If the document is related to the private or family life of a third party, protected by confidentiality under a special provision, or if it is crucial to a police, judicial or administrative investigation, the tax authority may deny the petition.
Tax authority governance
Is the tax authority subject to non-judicial oversight?
Every tax authority is subject to the control and monitoring of the Independent Authority for Public Revenues (see question 2).
Before the taxpayer initiates pre-court or court actions against an act or omission by the tax authority (see question 24), he or she may file a complaint to the Greek Ombudsman, an independent authority that intervenes in cases involving public bodies, including tax authorities. Upon examination of the complaint, the consumer adviser should attempt to contact the tax authority and resolve the issue.
Court actions (describe trial court actions in this section)
Which courts have jurisdiction to hear tax disputes?
Tax disputes fall within the jurisdiction of administrative courts, on two levels: the Administrative Court of First Instance and the Administrative Court of Appeals.
Tax disputes up to €60,000 and tax disputes arising from enforcement of tax claims by the tax authority (eg, seizures) fall under the competency of the single-member Administrative Court of First Instance.
Tax disputes from €60,000 and up to €150,000, as well as non-monetary tax disputes, lie within the competency of the three-member Administrative Court of First Instance.
If the tax dispute is valued at €150,000 or more, the three-member Administrative Court of Appeals has exclusive jurisdiction as a first and final instance.
Decisions issued by the Administrative Courts of First Instance may be appealed by any of the parties.
The territorial jurisdiction is determined by the seat of the tax authority that issued the contested act (or omission).
Final decisions issued by the Administrative Court of Appeals valued at more than €40,000 are subject to a petition for cassation before the Supreme Administrative Court on limited exclusively legal grounds and if no prior jurisprudence of the Administrative Supreme Court exists or if the decision of the Administrative Court of Appeal contradicts prior jurisprudence of the Administrative Supreme Court or other Supreme Court or irrevocable decision of an administrative court.
Greek law has introduced the ‘pilot trial’, a process by which any legal matter of an appeal before the administrative courts may be examined first by the Supreme Administrative Court directly upon the filing of a petition by the interested party, provided that the matter is of great importance and it affects many taxpayers. Moreover, an administrative court itself may issue a preliminary decision, initiating a pilot trial before the Supreme Administrative Court. The final decision by the Supreme Administrative Court is binding on the court that initiated the pilot trial and any party that was involved in the pilot trial and constitutes jurisprudence on the legal matter in the way described in the previous paragraph.
Lodging a claim
How can tax disputes be brought before the courts?
Tax disputes are brought before administrative courts as a recourse against any act or omission of the tax authority (including assessment of taxes and fines or the denial of refunds to the taxpayer, etc). A recourse may be brought by any taxpayer who has a legitimate interest affected by the contested act or omission, on any legal or factual grounds and without any threshold.
Recourse may also be brought independently by individuals or entities who are jointly liable for tax obligations of legal persons or entities. Tax disputes may not be brought before the courts by the tax authority.
The Code of Tax Procedure requires that before recourse to administrative courts, an administrative appeal before the DRD of the Independent Authority for Public Revenues is filed as mandatory. The administrative recourse may be submitted to the DRD within 30 days of the date of notification of the final corrective assessment act or other tax dispute, or 60 days for taxpayers residing abroad. The DRD must issue a decision within 120 days from the filing of the administrative appeal; otherwise the appeal is considered tacitly rejected.
The taxpayer has the right to judicially challenge such rejection by submitting an appeal to the administrative courts within 30 days of the date of notification of the decision issued by the DRD, or the expiry of the 120-day period if no decision was issued by the DRD. In any case, he or she is obliged to pay upon filing a court fee amounting to 1 per cent of the tax in dispute up to €1,000. Another court fee between €3,000 and €15,000 is payable for the hearing of the appeal at first instance.
Relief sought is limited to total or partial annulment or modification of the contested act, including an obligation to refund any amounts unduly paid to or due by the tax authority, with interest. In case of contestation of an omission by the tax authority, the taxpayer may request the court to determine the amount of the taxpayer’s claim.
Combination of claims
Can tax claims affecting multiple tax returns or taxpayers be brought together?
In principle, each contested act or omission by the tax authority is subject to a separate appeal. However, coherent act(s) may be contested in one appeal, especially in cases of tax audits covering multiple taxations and fiscal years. In any case, the admissibility of the appeal is judged separately for each contested act (deadline or court fee, etc). In cases where multiple persons or entities are jointly liable for payment of any amount of tax, an appeal may be brought together or separately for all or any of them. ‘Collective’ appeals by taxpayers are not permitted under Greek law.
Must the taxpayer pay the amounts in dispute into court before bringing a claim?
Payment of the amounts in dispute is not a prerequisite for the filing or hearing of an administrative appeal before the DRD or an appeal at first instance (except for the court fee mentioned in question 26).
The submission of an administrative appeal or an appeal suspends the payment of 50 per cent of the amount in dispute, provided that the remaining 50 per cent is paid. In any case, the taxpayer may seek suspension of the whole amount in dispute by the DRD or (more commonly) by the court, by proving inability to pay entailing irreparable damage in case of enforcement of the claim by the tax authority. In practice, it is difficult to obtain suspension and it requires the disclosure of the global income and assets of the taxpayer and his or her family members or, in case of legal entities, of jointly liable individuals, main shareholders and affiliated entities.
In case of an appeal before the administrative court of appeals against a decision of the Administrative Court of First Instance, the payment of 20 per cent of the amount determined by the court of first instance until the date of hearing before the Court of Appeal is a prerequisite for the appeal to be heard.
To what extent can the costs of a dispute be recovered?
The costs of a tax dispute may be sought by both the taxpayer and the tax authority. These only include costs connected to the proceedings before the court, in all instances. In practice, Greek courts only grant rather symbolic amounts as costs (a few hundred euros even for the Supreme Court). Court fees paid are refunded in full or in part in case of acceptance of the appeal.
Are there any restrictions on or rules relating to third-party funding or insurance for the costs of a tax dispute, including bringing a tax claim to court?
Greek law has no restrictions or rules relating to third-party funding or insurance for the costs of any dispute.
Court decision maker
Who is the decision maker in the court? Is a jury trial available to hear tax disputes?
Each party may file an appeal against a decision of the Administrative Court of First Instance within 60 days from the notification of the decision. A prerequisite for the hearing (but not filing) of the appeal is payment of 20 per cent of the tax levied (see question 27). The appeal may include any legal or factual ground.
Against decisions of the Administrative Court of Appeals, a petition for cassation may be filed within 60 days from the notification of the decision, or 90 days if the taxpayer resides abroad.
What are the usual time frames for tax trials?
Time frames in Greek administrative courts are notoriously long, but the situation is gradually improving (especially before the courts of appeal). An appeal before the Administrative Court of First Instance of Athens may be heard within three to five years from filing, and a decision is issued within six to 12 months from the hearing. Time frames before administrative courts in other cities are shorter. However, tax disputes involving amounts exceeding €150,000 are brought directly before the Administrative Courts of Appeal and heard within six to 12 months from filing. A decision is usually rendered within six months from the hearing. Time frames before the Supreme Administrative Court range from one to three years, according to the importance of the case.
What are the requirements concerning disclosure or a duty to present information for trial?
In principle, in trials before the administrative courts there is not a specific requirement to present information and each party bears the burden of proof of its own pleadings (see question 36). In any case, if the court does not have enough evidence, it may issue a preliminary ruling ordering a re-audit or supplementary audit with a limited scope, which is carried out by the tax authority.
What evidence is permitted in a tax trial?
Tax trials usually do not involve testimonies other than sworn statements (affidavits). In any case, the taxpayer is not accepted as a witness. The persons most commonly providing sworn statements or testimonies in tax trials include accountants, employees of the taxpayer or counterparties in various transactions. Experts or persons providing technical reports or legal opinions are also permitted to testify. All written evidence must be translated into Greek. Sworn statements or testimonies by non-Greek speakers are carried out with the assistance of a translator.
Who can represent taxpayers in a tax trial? Who represents the tax authority?
In tax trials with amounts in dispute exceeding €600, taxpayers must be represented by an attorney at law. The tax authority is represented either by its director or by members of the State Legal Council, a special body of lawyers representing the Greek state before all courts.
Publicity of proceedings
Are tax trial proceedings public?
All trial hearings before Greek administrative courts are public but, as explained, the procedure is basically on paper.
Burden of proof
Who has the burden of proof in a tax trial?
In principle, in trials before the administrative courts, each party bears the burden of proof of its own pleadings. However, in Greek tax law, the taxpayer has the burden to prove all elements that are necessary for a tax assessment, which constitute the reasoning of such tax assessment (usually in the form of a tax audit report). As a result, a tax assessment or audit may be annulled on the grounds of lack of reasoning. As an exception to this rule, Greek tax legislation often introduces presumptions for the indirect proof of the existence of taxable matter; in these cases, the burden of proof is reversed. Also, according to recent case law, in some extreme cases (eg, of tax evasion), the court may decide an ad-hoc allocation of the burden of proof, subject to judiciary review by the Supreme Administrative Court.
In any case, if the court does not have enough evidence, it may issue a preliminary ruling ordering a re-audit or supplementary audit with a limited scope, which is carried out by the tax authority.
Case management process
Describe the case management process for a tax trial.
In preparation for a tax trial, all evidence should be collected and translated and usually sworn statements are prepared. In certain cases, where additional legal grounds to the initial appeal exist, they can be submitted to the court 15 days before the hearing and notified to the other side and they become part of the appeal. Proxies or authorisation documents on behalf of the client should be submitted to the court at least one day before the hearing. The arguments of the appeal, the evidence and the counter arguments against the Greek state’s position are analysed in the legal memorandum submitted within three days from the hearing; and in the following three days, the legal memorandum of the Greek state (if any has been submitted) can be rebutted.
Can a court decision be appealed? If so, on what basis?
Each party may file an appeal against a decision of the Administrative Court of First Instance within 60 days from the notification of the decision. A prerequisite for the filing of the appeal is payment of 20 per cent of the tax levied (see question 27). The appeal may include any legal or factual ground.
Against decisions of the Administrative Court of Appeals, a petition for cassation may be filed within 60 days from the notification of the decision, or 90 days if the taxpayer resides abroad.