If a taxpayer disagrees with an assessment, they may file an application for administrative settlement before the Department of Internal Review of the General Committee of Public Revenues. The application must be made within 30 days of receiving the notice of assessment.

If the application for administrative settlement is rejected, the taxpayer may file an appeal with the administrative court. The appeal to the administrative court should be made within 60 days.

However, before the recourse to administrative courts, an administrative appeal is mandatorily to be filed before the Dispute Resolution Directorate (DRD). This appeal may be submitted to the DRD as follows:

• Within 30 days of the date of notification of the final corrective assessment or other tax dispute; or
• Within 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 as rejected.

For assessments, up to EUR 60,000, appeals will be heard by a single member of the Administrative Court of First Instance. For assessments, over EUR 60,000 up to EUR 150,000, appeals will be heard by a three-member bench of the Administrative Court of First Instance. In cases of assessments over EUR 150,000, appeals will be heard by the Court of Appeals.

In general, 20% (50% prior to 1 January 2017) of the tax in dispute must still be paid during the appeals process. However, a taxpayer may apply for full deferral of tax in certain cases.

In 2016, the government introduced revised penalty provisions for failure to file corporate tax returns or for filing of inaccurate returns, effective 1 January 2014, taxpayers, were provided with an option to apply the revised penalty to existing tax disputes currently pending before administrative courts or dispute resolution panel, provided the taxpayer withdraws from the dispute and accepts the findings of the tax audit. Such election was to be exercised within 90 days from notification of the new provision (i.e., by 16 January 2016).

COVID-19 Emergency Measures

In response to the COVID-19 pandemic, Greece announced the suspension of the following procedures and deadlines:

• Issuance of preliminary or final tax assessments and penalties by the tax authorities;
• Deadline for taxpayers to submit objections to preliminary tax assessments and penalties;
• Deadline for filing administrative appeals where the standard deadline expires during the period 11 March 2020 to 31 May 2020; and
• Deadline for Dispute Resolution Directorate to issue decisions on administrative appeals where the standard deadline expires during the period 20 March 2020 to 31 May 2020.