Greece is taking an important step towards preventive tax certainty with the introduction of Tax Binding Rulings, effective from 1 October 2026 onwards.
In their article published in Kathimerini, Maria Zoupa, head of Corporate Tax, and Diana Tsourapa, partner, discuss the new procedure, which allows taxpayers to obtain a binding interpretation from the Tax Administration on future facts, aligning Greece with established European practices.
The article highlights both the opportunities and the challenges of the new procedure, noting that while Tax Binding Rulings can offer meaningful legal certainty and protection from subsequent tax assessments, concerns remain regarding the high cost of access and the need for adequate reasoning in case of rejection.
As they note, with clear procedures, appropriately calibrated costs, and sufficient reasoning in every outcome, the binding rulings have the potential to become a reliable compass of interpretation for both the Tax Administration and taxpayers alike.