greece-vat

Worldwide VAT, GST and Sales Tax Guide

Transactions between related parties. The Greek VAT Code has incorporated Article 80 of the EU VAT Directive, regarding the imposition of VAT at the open market value for transactions performed between related parties, using as criteria whether the consideration is lower or higher than the open market value in conjunction with the supplier’s and recipient’s right to input tax deduction.

C. Who is liable

A taxable person is any entity or individual that makes taxable supplies of goods or services, intra-Community acquisitions, imports of goods into Greece or distance sales (if the relevant annual threshold is exceeded), in the course of business in Greece.

Exemption from registration. The VAT law in Greece does not contain any provision for exemption from registration, as there is no registration threshold.

Voluntary registration and small businesses. The VAT law in Greece does not contain any provision for voluntary registration, nor special VAT registration rules for small businesses.

Group registration. Group VAT registration is not allowed in Greece.

Holding companies. In Greece, a pure holding company cannot be a member of a VAT group, as group VAT registration is not allowed in Greece. A pure holding company will still be required to be registered for VAT in Greece, even if it makes no taxable supplies. This would be declared at the time of registration. A VAT registration must be made irrespective of the level of taxable supplies.

Cost-sharing exemption. The VAT cost-sharing exemption, in accordance with VAT Directive 2006/112/EEC Article 132(1)(f), has not been implemented in Greece.

Fixed establishment. The Greek tax authorities have not issued any guidelines as to the concept of a fixed establishment for VAT purposes; thus, reference is made only to the VAT Implementing Regulation No 282/2011 as in force.

Non-established businesses. A “non-established business” is a business that does not have an establishment in Greece. A foreign or non-established business should register for VAT in Greece, if it engages in any of the following taxable activities:

• Supply of goods that are located in Greece at the time of supply

• Intra-Community acquisitions

• Distance sales in excess of the annual threshold (EUR10,000)

• Imports

• Services, to which the reverse charge does not apply

Apart from the above cases, the reverse charge generally applies to supplies of services made by non-established businesses to taxable persons (subject to the default business-to-business (B2B) rule). Under this measure, the taxable person that receives the supply should account for the Greek VAT due. If the reverse charge applies, the non-established business is not required to register for Greek VAT.

The reverse charge does not apply to supplies of goods or services made to private persons.

Tax representatives. A foreign business, non-established and non-registered in Greece, should obtain a Greek VAT registration number before making taxable supplies in Greece.

In general, a non-EU business must appoint a tax representative, called locally a VAT fiscal representative, to register for VAT. (An exemption applies for registration under the non-Union scheme of OSS.) The VAT fiscal representative should be given, among other documents required by law, a power of attorney to act on behalf of the non-established business.

The VAT fiscal representative should be appointed and obtain registration before the non-established business begins to make taxable supplies. The VAT fiscal representative may be any person engaged by the business who is a resident and VAT liable in Greece, such as a legal entity or an accountant. The VAT fiscal representative undertakes compliance procedures and may be held jointly liable for VAT debts with the foreign business that it represents.

An EU business is not required to appoint a VAT fiscal representative to register for VAT in Greece but may opt to do so. If a VAT fiscal representative is appointed at the foreign EU business’s option, such VAT representative undertakes compliance procedures and may be held jointly liable for VAT debts of the foreign EU business.

Reverse charge. In general, VAT due on cross-border B2B supplies of services shall be due at the place where the customer is situated. Where the reverse-charge procedure applies, the Greek recipient must act as both supplier and recipient of the services for VAT purposes. That is, the Greek customer should account for both output and input tax on the VAT return.

Domestic reverse charge. Domestic reverse charge applies in the case of supplies of scrap, recyclable goods and gas emission rights pursuant to Article 45 of the Greek VAT Code on certain conditions.

Moreover, a domestic reverse-charge mechanism applies to construction works on real estate provided by private contractors to local municipalities or other public bodies, where the latter are acting as taxable persons for VAT purposes. In some of these cases, no Greek VAT is charged on the invoice issued by the private contractor (supplier) to the municipality or other public body, and the supplier is not required to account for VAT but is required to indicate on the invoice a special wording indicating application of this regime as follows: “Article 45 of the Greek VAT Code – domestic reverse charge.” The supplier has a full right to deduct input tax incurred in relation to such supplies.

In addition, a domestic reverse charge applies to B2B supplies of mobile phones, game consoles, PC tablets and laptops. For such supplies, the Greek supplier must issue an invoice as a domestic supply and not charge VAT and include special invoice wording indicating application of this regime. The buyer must account for VAT via the reverse-charge mechanism. The identity of the buyer as taxable person with the right to deduct input tax should be verified through a specific online process powered by the Independent Authority of Public Revenues.

Digital economy. Specific VAT rules apply to cross-border supplies of goods and services sold via the internet (e-commerce) in all EU Member States, effective 1 July 2021. These rules apply to all direct sales to nontaxable persons (in practice these are mostly private individuals), but we refer to these rules as e-commerce VAT rules because most of these transactions are conducted via the internet. In general, the place of supply is in the country of consumption, i.e., where the goods are shipped to or where the buyer of the goods or services resides, subject to any “use and enjoyment” provisions that may override this rule (see Section B, Effective use and enjoyment subsection above). Therefore:

• For supplies of services made by a nonresident supplier to a business customer (B2B), the business customer is responsible for accounting for the VAT due, using the reverse charge.

• For supplies of goods made by a nonresident supplier to a business customer (B2B), where the goods are transported from another EU Member State, the business purchasing the goods is responsible for accounting for the VAT due, as an intra-Community acquisition. If the goods come from outside the EU, the purchaser may have to report an importation of goods.

• For supplies of goods or services made by a nonresident supplier to a final consumer (B2C), the supplier is generally responsible for charging and accounting for the VAT due at the rate applicable in the customer’s country (unless the supplier’s sales fall beneath the distance selling threshold of EUR10,000 with effect from 1 July 2021). This VAT can be reported using a single VAT registration, using a “One-Stop-Shop” mechanism.

The use of the IOSS special scheme is not mandatory. If VAT is not collected via the IOSS scheme, the importation of goods into the EU is subject to import VAT in the country of final destination and the Member State can decide freely who is liable to pay the import VAT, which could be the customer or the seller (or an electronic interface).

The taxable person who uses this special scheme is granted a unique individual VAT tax registration number for the application of the special scheme with the prefix IM, which is notified by electronic means.

The intermediary is granted a unique individual tax registration number with the prefix IN, by electronic means and a unique individual VAT tax registration number with the prefix IM for the application of this special regime for each taxable person for whom it has been set. The VAT tax registration number or tax registration number issued shall be used exclusively for the purposes of this special scheme.

The user of the OSS and IOSS submits, by electronic means, a VAT return for each calendar quar ter, whether supplies under this special regime have been provided or not. The VAT return is submitted by the end of the month following the end of the tax period covered by the return. Required modifications of the declared data are included in the next VAT return, within three years from the expiration of the deadline for submission of the initial return.

The tax is paid simultaneously with the submission of the return and at the latest at the expiration of the deadline for its submission, in euros, to a bank account designated specifically for this purpose and kept at the Bank of Greece, with reference to the relevant VAT return. There is no right to deduct the input tax paid in Greece, but there is a right to refund. Exceptionally, if the subject in question is required to account for VAT in Greece for activities not covered by this scheme, then it is entitled to a deduction of input tax paid in Greece and relates to their taxable activities under this scheme.

For more details about the IOSS, see the EU chapter.

Postal Services and Couriers Scheme. If the IOSS is not used and the customer is liable for the import VAT due on the supply (and importation) of consignments with a small intrinsic value (i.e., less than EUR150), the VAT can be collected using the special scheme for postal services and couriers.

In Greece, the Postal Services and Couriers Scheme is known as “Special Arrangements” scheme can be used when the IOSS scheme is not used and only if the Member State of destination of the goods coincides with the Member State of import.

• The parcel consignee becomes liable to pay the respective import VAT. However, VAT is paid by the person who brings the goods before the customs office on behalf of the consignee, i.e., as a rule, the international courier companies and the domestic postal service provider (ELTA).

• The VAT payment is deferred until the 16th day of the month following the one when it was assessed, whereas no special permission and/or guarantee is required.

• Persons using Special Arrangements are obliged to maintain import records for a period of 10 years.

For more details about the special scheme for postal services and couriers, see the EU chapter.

Online marketplaces and platforms. Under the new EU VAT e-commerce rules, effective 1 July 2021, taxable persons that “facilitate” certain B2C sales of goods are deemed to have purchased and then supplied those goods themselves. This means that the single supply from the “underlying” supplier to the final consumer is split into two deemed supplies:

• A supply from the supplier to the facilitator (deemed B2B supply).

• A supply from the facilitator to the final customer (deemed B2C supply). Any intermediation service provided by the facilitator is disregarded for VAT purposes.

This provision does not cover all sales facilitated via the facilitator. It only covers distance sales of goods imported from non-EU jurisdictions in consignments with an intrinsic value not exceeding EUR150. The jurisdiction of residence of the supplier using the facilitator is irrelevant. The supply to the facilitating platform is VAT exempt and the supplies made by that platform follow the e-commerce VAT rules as described above. In addition, the provision also covers sales within the EU, if the supplier is not established within the EU. This applies to both local shipments within one Member State as well as intra-Community shipments. In both cases, the final customer must be a nontaxable person.

In Greece, there are no additional specific local rules that apply.

For more details about the rules for online marketplaces, see the EU chapter.

Vouchers. As of 1 January 2019, vouchers, either physical or electronic form, are acceptable as consideration in exchange for the supply of goods or services.

The goods or services to be supplied or the identities of their potential suppliers are either indicated on the instrument itself or in related documentation, including the terms and conditions of use of such instrument.

Vouchers are distinguished between “single-purpose vouchers” (SPVs), where the place of supply of the goods or services to which the voucher relates and the VAT due on those goods or services are known at the time of issue of the voucher, and “multipurpose vouchers” (MPVs), which are vouchers other than SPVs.

The essential difference between the two categories of vouchers is their VAT treatment. In SPVs, the taxable event is their distribution and not the subsequent supply of goods or services. In MPVs, VAT is due at the time of their redemption, when the goods or services to which the voucher relates are supplied, whereas any prior transfer of them should not be subject to VAT.

Intermediary services for the distribution of vouchers that are supplied by taxable persons should be subject to VAT.

Transport tickets, admission tickets to cinemas and museums, postage stamps and instruments entitling the holder to a discount upon purchase of goods or services but carryingm c no right to receive such goods or service should not be treated as vouchers.

Registration procedures. Businesses established in the EU that are required to register locally in Greece can do so and obtain a Greek VAT registration number:

• By directly applying electronically in a simplified process aimed at EU businesses with no prior registration or establishment in Greece, in which case the appointment of a VAT fiscal representative is not required Or

• By filing in hard copy an application form along with all required documents (power of attorney, standard tax forms provided by the Greek tax office, a memorandum of association and a certificate of taxable status) and by appointing locally a VAT fiscal representative.

Businesses established outside the EU that are required to register locally for VAT purposes in Greece are required to appoint a local VAT fiscal representative. No electronic registration is available.

In some cases, the appropriate local tax office shall not grant the requested Greek VAT registration number to the applicant (foreign business), for example, if the business had already obtained a Greek VAT registration number.

Deregistration. A taxable person that ceases to be required to account for Greek VAT may opt to deregister. If such taxable person is not deregistered, he must continue complying with all relevant filing obligations.

The basic time of supply for goods is when the goods are put at the purchaser’s disposal. If the supplier undertakes the obligation to forward the goods to the buyer, the time of supply is at the beginning of the transportation. For installed goods, the time of supply is when installation is completed. If the supplier issues an invoice before the basic time of supply, the time of supply becomes the invoice date.

In general, the time of supply for services is when they are performed. If the supplier issues an invoice before the basic time of supply, the time of supply is the invoice date.

Deposits and prepayments. Payments received before the supply of goods or services, or the issuance of a VAT invoice are known as advance payments. Advance payments do not generally create a tax point (they create a tax point only in the event of an intra-Community supply of services).

Continuous supplies of services. If services are provided continuously, the tax point is the time that any amount is considered as payable.

Goods sent on approval for sale or return. The tax point for a local supply of goods sent on approval for sale or return is when the goods are approved for receipt and sold. If the goods are returned, there is no supply.

Reverse-charge services. There are no special time of supply rules in Greece for supplies of reverse-charge services. As such, the general time of supply rules applies (as outlined above). This means that the time of supply of services is when the services are performed unless an invoice is issued before the basic time of supply.

By way of derogation if any advance payment is collected prior to the completion of the EU cross-border services, the tax point is at that time. A special tax record (titled “special tax record for VAT purposes for intra-EU supplies of services”) is issued at the time of the advance payment collection and has the same content as a VAT invoice.

For continuous supplies of intra-EU cross-border services, the VAT becomes due by the end of the tax year, to the extent that no installments have been paid during the period of the supply. A special tax record should be issued.

The reverse-charge mechanism only applies to B2B cross-border services, not goods. For intraEU acquisition of goods, refer to the Intra-Community acquisitions of goods subsection below.

Leased assets. Lease of assets is considered to be a supply of services; thus, the tax point is the time that any amount is considered to be payable. If at the expiration of the lease agreement, the lessee takes ownership of the assets, this should be considered to be a supply of goods and the tax point shall be the time when the sale is performed.

Imported goods. The time of supply for an importation is when the importation occurs or when the goods leave a duty suspension regime.

Intra-Community acquisitions. For intra-Community acquisitions, the time of supply is when the goods are put at the purchaser’s disposal. If the supplier undertakes the obligation to forward the goods to the buyer, the time of supply is the beginning of the transportation. VAT is due on the issuance of an invoice or by the 15th day of the month following the month in which the supply took place, whichever is the earlier.

Intra-Community supplies of goods. For intra-Community supplies, VAT is due upon the issuance of the respective invoice and at the latest on the 15th day of the month following the one on which the supply was affected.

Distance sales. The time of supply rule for the supply of distance sales is at the beginning of the transportation.

provided that a court order has been issued beforehand; however, this exception has rarely been applied in practice.

Noneconomic activities. Input tax incurred on purchases that are used for noneconomic activities is not recoverable in Greece.

G. Recovery of VAT by non-established businesses

Input tax incurred by non-established businesses that are not registered for VAT in Greece is recoverable. Greek VAT authorities refund VAT incurred by businesses that are neither established nor registered for VAT in Greece. Non-established businesses may claim Greek VAT to the same extent as VAT-registered businesses.

EU businesses. For businesses established in the EU, refunds are made under the terms of the EU Directive 2008/9/EC. The VAT refund procedure under the EU Directive 2008/9 may be used only if the business did not perform any taxable supplies in Greece during the refund period (excluding supplies covered by the reverse charge). For full details, see the EU chapter.

Find below specific rules for Greece:

• Claims should be submitted electronically in either Greek or English and should be accompanied by scanned copies of relevant invoices placed in an electronic archive or file.

• The appropriate Greek authority for this purpose is the following:

Independent Authority for Public Revenue

General Directorate of Tax Administration

Directorate for the Implementation of Indirect Taxation Section C – VAT Refund to companies having their registered office within and outside the EU.

Sina Street 2-4 10672 Athens Greece

• If the refund application is approved, refund of the approved amount should be paid within 10 working days after the expiration of the deadline to respond. Interest is payable to the applicant on the amount of the refund to be paid if the refund is paid after the last date for payment. Interest due is calculated according to the rules applicable for payment of default interest to Greek taxable persons.

Non-EU businesses. For businesses outside the EU, Greece does not refund VAT under the terms of the EU 13th Directive. This includes the United Kingdom (UK). However, this is with the exception of businesses established in Norway, Switzerland and Northern Ireland. A Norwegian or Swiss business may claim Greek VAT refunds to the same extent as a Greek taxable person. Transactions involving the movement of goods between Northern Ireland and the EU Member States are treated as intra-Community acquisitions and supply of goods, for a four-year period from 1 January 2021.

Find below specific rules for Greece:

• The refund application must relate to the supply of goods and services or imports covering a period of at least three months and not exceeding one calendar year.

• The period may be less than three months when it represents the remainder of a calendar year.

• Refund claim is submitted in the Member State of establishment by 30 September of the calendar year following the return period.

• Claims relating to UK, Norwegian and Swiss businesses must be filed in hard copies before the VAT Division of the Greek Ministry of Finance.

Late payment interest. In Greece, interest is not paid on late refunds to non-established businesses (for both EU and non-EU non-established businesses).

H. Invoicing

VAT invoices. A taxable person should generally provide a VAT invoice for all taxable supplies made, including exports and intra-Community supplies. For retail transactions, retail receipts should be issued.

A valid original VAT invoice is required to support a claim for input tax deduction or a refund under the EU 8th Directive refund scheme (see the EU chapter).

Credit notes. A VAT credit note may be used to reduce the VAT charged and reclaimed on a supply. A credit note should be cross-referenced to the original VAT invoice. It is possible to issue a credit invoice only for the VAT amount in cases where VAT has been erroneously charged under certain conditions.

Electronic invoicing. Electronic invoicing is mandatory in Greece for certain taxable persons.

Scope of electronic invoicing. For business-to-government (B2G) supplies, electronic invoicing is mandatory for all taxable persons in Greece. This is in line with EU Directive 2014/55/EU (see the EU chapter).

For B2B and B2C supplies, electronic invoicing is allowed but not mandatory in Greece. This is in line with EU Directive 2010/45/EU (see the EU chapter)

For B2G supplies, the obligation of contracting authorities and contracting bodies was extended to receive and process e-invoices issued in the context of Public Procurement Contracts of L.3978/2011, L.4412/2016, and L.4413/2016 regardless of their estimated value. The obligation of the economic bodies for e-invoicing applies to:

• Contracts concluded in the sectors of defense and security, in accordance with L.3978/2011

• Public procurement contracts and those relating to works, designs, technical and other related scientific services, as well as supplies and general services, in accordance with L.4412/2016

• Concession agreements, in accordance with L.4413/2016

• Any expense category incurred by contracting authorities or bodies

As a general rule, the time point for the commencement of the mandatory regime of e-invoicing appears to be the date by when the process for the conclusion of the relevant contract commences (said time point is determined on a case-by-case basis by the provisions of L. 3978/2011, 4412/2016 and 4413/2016) and not the date of issuance of the invoice.

A gradual inclusion to the mandatory e-invoicing regime is provided depending on the body to which the contracting authorities belong, as well as the legal framework governing the relevant expenses, starting from 12 September 2023.

An explicit provision referring to the economic body’s obligation for issuance of e-invoices should be included in the relevant contract.

There is no obligation for e-invoicing for:

• Public contracts of minor value, i.e., value equal to or less than EUR2,500 excluding VAT

• Public contracts concluded between entities of the public sector, when these entities are acting in a noncompetitive manner and outside of any procedure addressed to the market (i.e., when they are not acting as economic bodies)

• Other general government expenditure up to EUR2,500, which do not fall within the scope of L.3978/2011, L.4412/2016 and L.4413/2016

• Contracts that fall within the scope of L.3978/2011 (procurements related to defense and security) and are classified as secret

For electronic invoices in general:

• The use of a licensed service provider is required (the list with the licensed service providers can be found here aade.gr/en/mydata/licensed-software-e-invoicing-providers) so that to ensure

real time transmission to myDATA digital platform, as well as the authenticity of the e-invoice through the QR code that must be indicated there in. In addition, e-invoices undergo basic controls by myDATA digital platform and bear the “unique entry number,” which must be indicated on every invoice issued by licensed software.

• Another option for the issuance of electronic invoices and real-time transmission to myDATA digital platform is through the free application of IAPR called “timologio” (aade.gr/en/timologio). The application is addressed to all businesses that either do not have a computer system or the system they use does not cover their daily needs. Through a fully configurable environment, a company can develop its profile and its customers list, organize its products and services, issue its documents and transmit all the necessary information to myDATA digital platform in real time.

From the tax year 2021, Greek established taxable businesses are liable to use electronic maintenance of their accounting books (e-books).

In a nutshell, all Greek established taxable persons are liable to digitally transmit their transactions’ data (revenues invoices/sales receipts), as well as the classification of both their revenues and expenses, to the Independent Authority of Public Revenues (IAPR) through a specific digital platform (myDATA) as of 1 January 2021. The deadlines for the data transmission and for the classification thereof are defined in Decision A.1138/2020, as updated and currently in force. Real time reporting is in general mandatory except from specific cases enumerated to the Decision A. 1138/2020. However, this is not applicable for foreign taxable persons that have only acquired a Greek VAT number (without operating through a Greek permanent establishment).

Gradual elimination of tax declaration deviation limits. Permissible discrepancies between tax declarations and the information reported to the myDATA platform have been abolished gradually. The schedule for reducing the deviation limits was as follows:

From 1 July 2024 to 30 September 2024, the rate decreased to 10% for revenue and 20% for expenses.

from 1 October 2024 to 31 December 2024, the rate was 0% for revenue and 5% for expenses.

Starting 1 January 2025, there are no permissible deviation limits for revenue and expenses data in VAT tax declarations in relation to the data on the myDATA platform.

The aforementioned deviation limits should be viewed together with the deductibility limitation ‒ the expenses declared in the VAT return shall not exceed those transmitted to myDATA digital platform; otherwise, any excess expense amount will not be recognized for input VAT deductibility purposes.

For the EU VAT in the Digital Age (ViDA) proposals, refer to the EU chapter.

Simplified invoices. Simplified invoices are allowed when either the amount of the invoice does not exceed EUR100, or the issued invoice is a document that modifies and refers specifically and indisputably to an original invoice. The main difference with the regular invoice is that the simplified invoice does not contain the recipient’s/customer’s data. Simplified invoices must contain at least the following details:

• The date of issue

• Identification of the taxable person supplying the goods or services

• Identification of the type of goods or services supplied

• The amount of VAT payable or the information needed to calculate it

• If the simplified invoice intends to amend an initial invoice, a reference to the initial invoice and the specific details that are amended must be made

Self-billing. Self-billing is allowed in Greece. The seller is allowed, subject to prior (written or oral) agreement, to ensure the issuance of an invoice from the recipient of the goods or services

(self-billing) or by a third party on behalf of the seller. The agreement to issue an invoice by the recipient of goods or services or from another third party does not exempt the taxable person from the legal obligation to ensure that an invoice is issued, as well as from any relevant liability.

Proof of exports and intra-Community supplies. VAT is not chargeable on supplies of exported goods or on intra-Community supplies of goods. However, to qualify as VAT-free exports and intra-Community supplies, they should be supported by evidence confirming that the goods have left Greece. Acceptable proof includes the following documentation:

• For an export, copies of the export document reporting the electronic message “IE 599: Export Completion Notification” indicating the supplier as the exporter, the bill of lading issued by the transporter, the sales invoice and bank proof of payment (if applicable).

• For an intra-Community supply, a range of commercial documentation, such as dispatch notes, the bill of lading and proof of payment.

No special documentation applies in Greece for evidencing the application of the Quick Fixes. Normal intra-Community documentation rules apply. However, for goods transported via means of transport of public use, article 45a of the VAT Implementing Regulation No. 282/2011 applies. As per this article, a written statement from the acquirer, stating that the goods have been dispatched or transported by the acquirer, or by a third party on behalf of the acquirer, and identifying the Member State of destination of the goods is one of the documents that evidence the VAT exemption for intra-EU supplies. However, there is no official template for this document, published by the Greek tax authorities.

Foreign currency invoices. If an invoice is received in a foreign currency, the VAT amounts should be converted into the domestic currency, which is the euro (EUR). The exchange rate to be used is issued by the IAPR. An invoice may be issued in foreign currency if Greece is the place of supply of goods or services and if the amount of VAT payable is indicated at least in euros.

Supplies to nontaxable persons. For supplies to nontaxable persons, a sales receipt must always be issued. Sales receipts (as well as any other tax records issued in the framework of B2C sales) must be issued through use of online tax mechanisms (FIM), compatible with the interface requirements with IAPR, or through the use of third-party licensed service providers. However, the Greek legislation provides for specific exemptions in this respect, for example, in cases of toll receipts or electricity and telephone bills.

Distance selling. For intra-Community distance sales made B2C, a full VAT invoice must be issued (to the extent the seller operates under a Greek VAT number). However, if the supplier operates the OSS regime, then no full VAT invoice is required unless requested. Persons registered to IOSS scheme in Greece shall issue the relevant documents for the sale of goods in accordance with the invoicing rules of Greek Accounting Standards (L. 4308/2014).

Records. In Greece, examples of what records must be held for VAT purposes include tax records, accounting books and relevant supporting documents. This applies for Greek established entities. In Greece, VAT books and records can be kept outside of the country. This is on the condition that they can be submitted to the Greek tax authorities, in the case of an audit, within a reasonable time.

Non-established businesses operating in Greece through a Greek VAT number should ensure to maintain all the tax records issued and received through its Greek VAT number, signed CMRs and transport documents, bank statements, and import and export documents, as well as any other supporting document that could be used in the case of a VAT audit by the Greek tax authorities. Such records can be kept outside the country; however, in the case of an audit, the records must be submitted to the Greek tax authorities, within a reasonable time.

Record retention period. The records retention period is linked to the statute of limitations period, within which the tax authorities can lawfully impose taxes. Tax Procedures Code (law 5104/2024)

sets out a five-year statute of limitation period, commencing from the end of the tax year in which the deadline to submit tax return expires.

Electronic archiving. Electronic archiving is allowed in Greece. It is allowed as long as there is a system for searching, displaying and printing or reproducing the records, in order to assist a potential audit by the tax authorities. Records created in a printed format can be digitized and stored in the new format even during the current tax year. For each invoice, the data that ensures the authenticity and integrity of the content of the document must be safeguarded.

I. Returns and payment

Periodic returns. The VAT return due should be filed by the last business day of the month following the end of the return period. Greek periodic VAT returns are submitted electronically as follows:

• Monthly, if the taxable person maintains double entry accounting books

Or

• Quarterly, if the taxable person maintains single entry accounting books (this is also the case of foreign VAT-registered persons)

No VAT return is required if a taxable person has suspended its business activity and has declared such suspension with the appropriate tax office. This refers to either the termination of the business activity or the “deactivation” of a non-established business’s Greek VAT number. If said taxable person wishes to perform in the future taxable transactions in Greece, it may “reactivate” the same Greek VAT number.

Special provisions apply for the Greek-established entities with respect to the filing of the VAT returns in connection with the invoices transmitted to the myDATA digital platform. From 1 January 2024 onward, the revenues included in the VAT return shall not be less and the expenses shall not exceed those transmitted to myDATA digital platform; otherwise, any excess expense amount will not be recognized for input VAT deductibility purposes.

Periodic payments. In principle, filing of VAT returns and full payment of the VAT due should be made by the last business day of the month following the end of the return period. However, in the case of VAT returns filed on time, taxable persons have the option of paying the VAT due in two equal installments provided that the total VAT amount payable exceeds EUR100. If they choose installments, the first installment is due by the last business day of the month during which the VAT return was submitted, and the second installment is due by the last business day of the following month. Payment of VAT must be made electronically (see the Electronic filing subsection below).

Electronic filing. Electronic filing is mandatory in Greece for all taxable persons. VAT returns should be filed electronically through myAADE (that is, the electronic application of the IAPR). This is mandatory for all VAT taxable persons, Greek-established companies and foreign VATregistered companies.

Payments on account. Payments on account are not required in Greece.

Special schemes. Small enterprises. Taxable persons whose turnover exclusive of VAT during the previous tax year did not exceed the EUR10,000 threshold are exempted from the obligation to file VAT returns and from VAT payment, provided that they apply for and are registered as “small enterprises falling under the regime of Article 44 of Greek VAT Code.” The EUR10,000 threshold must neither include disposals of capital assets nor exempt supplies with no right of deduction.

Newly Greek VAT-registered businesses may also apply for the special scheme. In addition, it is also no longer obligatory to retain the special scheme for two years.

payment or set-off or VAT. The respective punishment varies from 2 to 20 years depending on the amounts involved in the tax evasion. In particular:

• Imprisonment of at least two years and up to five years is imposed if the annual non-paid VAT amount is up to EUR50,000.

• Imprisonment for at least 5 years and up to 20 years is imposed if e the annual non-paid VAT amount exceeds EUR100,000.

In addition, the law states that any person who knowingly signs an inaccurate tax return as a proxy or any other person who knowingly contributes or provides direct support to the commission of tax evasion (including company’s officers) is punished as a direct accomplice.

Personal liability for company officers. The penal sanctions stated above can also apply to a company’s officers if an intention of fraud is identified.

Statute of limitations. The statute of limitations in Greece is five years. This commences from the end of the tax year in which the deadline to submit tax return expires.