The Independent Authority for Public Revenue (AADE) in Greece is moving to correct tax errors retroactively, covering cases dating back to January 1, 2014—even when disputes have already reached the Dispute Resolution Directorate or the administrative courts.
These corrections may be initiated either by the taxpayer or automatically by the Tax Administration. When errors are identified, any taxes or fines that were incorrectly assessed or paid will be cancelled or refunded, overriding the usual statute of limitations.
For instance, if a serious mistake has been made—whether a miscalculation or a fundamental misunderstanding of a taxpayer’s obligation—the authorities can now intervene without being bound by past bureaucratic rigidity.
AADE may amend or annul tax assessments, whether immediate, estimated, corrective, or penalty-related. This can occur upon the taxpayer’s request or automatically, in cases of obvious errors such as a non-existent tax obligation or a numerical miscalculation. Numerical errors include mistakes in arithmetic or calculation—for example, charging 10,000 euros instead of 1,000 euros.
However, misinterpretations of tax law, wrongful exemptions, or incorrect application of legislation do not fall into this category.
To request an amendment or annulment, taxpayers must provide clear supporting evidence, unless the relevant documents are already held by the tax office. Complex checks are not required—only straightforward proof of the mistake.
According to the relevant Article of the Tax Procedure Code, if a case has already gone to court, correction remains possible for one year after a final ruling. Importantly, the error does not need to have been raised during the trial; if it is evident, the tax administration retains the power to correct it later.