Administrative tax objection to the Dispute Resolution Directorate (Greece)

Published byDocMuse

The objection (ενδικοφανής προσφυγή) against an act of Greece's tax authority, ΑΑΔΕ — a corrective tax assessment, a fine — which must be made before any court action, written as a complete document ready to upload to myAADE: the act, the amount contested, the grounds, the evidence and the request. Under art. 72 of Greek Law 5104/2024 it is filed within 30 days of notification (60 for residents abroad, August not counted), and the Dispute Resolution Directorate decides within 120 days. It includes the choice on suspending 50% and the request to suspend the rest.

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Common questions

How long is there to object to an act of ΑΑΔΕ, the Greek tax authority?

30 days from notification of the act, or 60 days for people living abroad (art. 72 of Greek Law 5104/2024, the Tax Procedure Code). August is not counted. The objection is compulsory before any court action, so if the deadline is missed the act as a rule can no longer be challenged. Enter the date of notification in the document.

How is a Greek tax objection filed through myAADE?

Only electronically: since 1 February 2023 the objection has been filed exclusively through myAADE, with Taxisnet credentials, and not by post or at the tax office. The objection is uploaded as a file, with its attachments. This document is written for exactly that: fill it in, download it as a PDF and upload it together with the act and the evidence.

Does the tax have to be paid while a Greek tax objection is pending?

In part. Filing the objection suspends collection of 50% of the amount contested, provided the other 50% has been paid. With the objection, a request can be made to suspend collection of that 50% too; the Dispute Resolution Directorate grants it only if it finds that paying now would cause irreparable harm, so give evidence of it. Section 4 of the document offers both options and the option of asking for no suspension. If the objection succeeds, what was paid is refunded.

What if Greece's Dispute Resolution Directorate does not decide within 120 days?

The Dispute Resolution Directorate decides within 120 days, in which August is not counted either. If that time passes without a decision, the objection counts as tacitly rejected. From then on, or from notification of a decision that does not satisfy the taxpayer, the way to the administrative court is open, with its own deadline. Consult a lawyer early about that deadline and the competent court.