The process is largely automated, through a dedicated platform launched by the Independent Authority for Public Revenue (AADE) for filing a declaration of acceptance of audit findings
Taxpayers have up to five opportunities to cut the fines arising from a tax audit by as much as half, provided they accept the principal amount owed within the time limits set by the procedure. The size of a tax office fine therefore no longer depends solely on the outcome of the audit, but also on when the taxpayer chooses to close the case.
The Tax Procedure Code sets out four successive stages of acceptance, with a discount that scales from 25% up to 50%. The process is largely automated, through a dedicated platform launched by AADE for filing a declaration of acceptance of audit findings.
For small and medium-sized businesses, freelancers and the self-employed, who often face tax audits, reaction time can prove decisive. The earlier the debt is accepted, the greater the reduction in the fine.
The sooner, the better
The arrangement is contained in the new Article 75 of the Tax Procedure Code and provides for a graduated reduction in fines, depending on the stage the tax audit has reached.
Anyone wishing to close an audit swiftly must use the digital service for submitting the declaration of acceptance on the myAADE platform, by selecting: Applications, Tax Services, Declaration of Acceptance of Audit Findings, Article 75 of Law 5104/2024.
The largest discount (50%) is granted when the taxpayer accepts the audit findings at the initial stage, before the assessment is even finalised. This is the point at which the person under audit has already been informed of the tax authority’s findings, but has not yet moved on to the administrative appeal procedure.
For a small business or a self-employed person, this option can significantly reduce the overall burden, provided that the violation and the assessment are accepted by the person under audit, and that the taxpayer has the financial means to meet the terms of the procedure.
That is because acceptance is not merely a declaration of intent. It is tied to specific deadlines and requires the timely payment of the amounts due.
The discount shrinks the longer the case remains open
If the taxpayer does not accept the findings at the initial stage, they can still reduce the fine by up to 40% after notification of the final act of corrective assessment of tax, levy or contribution.
This option remains available for as long as the deadline for lodging an administrative appeal with the Dispute Resolution Directorate runs. The taxpayer now knows the exact amount being charged and can either contest the act, in order to have the fines cancelled in full if they do not accept the violation, or settle the dispute by accepting the principal debt. At this stage, however, the discount is smaller than at the initial stage, depending on the facts of the case and the grounds the taxpayer invokes.
The procedure is particularly important for those who cannot afford lawyers, accountants and legal costs in order to pursue a tax dispute with the state to the end. Although a single free application, submitted electronically to the Tax Dispute Resolution Directorate (DED) through the AADE platform, is often enough, an appeal to the DED demands time, preparation and solid legal substantiation. The case also remains open until the person under audit receives the DED’s decision, or until the deadline for a reply expires (a “tacit rejection”).
Even if the appeal to the DED does not succeed, there is still a “window” for settlement and a discount, although at this stage the reduction in the fine is limited to 30%. Acceptance of the audit findings can be submitted electronically after notification of the decision of AADE’s Dispute Resolution Directorate, or after a tacit rejection, for as long as the deadline for lodging a court appeal is running.
This stage allows the taxpayer to change course, even if they initially chose to contest the assessment. The financial benefit is smaller than at the earlier stages, but it remains an available route to a final settlement of the tax liability at a reduced cost.
Even before the hearing
The fourth option provides for a 25% reduction in the fine once the dispute has reached the administrative courts. Acceptance can still be made, up to and including the day before the originally scheduled hearing date.
In this way, the person under audit can end the court battle even at an advanced stage, just hours before reaching the courtroom. The discount is the smallest of the four alternatives, but it serves as a last opportunity to avoid continuing the dispute.
In every case, close attention to dates is essential. Missing the deadline at any stage can mean losing the corresponding benefit. For this reason, the choice between accepting and contesting the act should be made only after calculating the total amount, the room for payment and the likelihood of success at each step or appeal.
An upfront payment and up to 12 instalments for the balance
A condition common to all stages for securing the reduction is payment of 25% of the amount due within just three days of accepting the audit findings.
The remaining 75% can be settled through the standing arrangement in up to 12 instalments. This is a special facility for taxpayers who cannot pay the entire debt in one go, though it does not remove the need to keep strictly to the payment schedule.
If instalments are not paid on time and the terms of the procedure are breached, the reduction may be lost, with the debt reverting to its original amount once payments already made have been taken into account.
The underlying logic of the system is a bigger discount at the start of the assessment and a smaller one as the case progresses from the tax audit to the final act, the DED and ultimately the courts. The procedure is linked to efforts to ease the pressure on the courts and reduce the number of pending cases, as well as to a modern trend towards a tax administration that does not confine itself to imposing penalties, but gives genuine room for compliance and settlement. In that spirit, as Minister of National Economy and Finance Kyriakos Pierrakakis has put it, “the role of the State is to extend a hand, not wag a finger at the citizen”.
The Out-of-Court Resolution Committee
Alongside, and beyond, the Article 75 procedure, the Out-of-Court Tax Dispute Resolution Committee remains an additional mechanism for out-of-court settlement in cases that fall within its remit.
A law published on 25 June 2026 introduced new deadlines for the operation and completion of the Committee’s procedures, amending Article 16 of Law 4714/2020.
Under the new law passed this summer (Law 5313/2026), applications must be submitted electronically by 30 June 2027. The request may concern only cases that are pending, but have not yet been heard, before the Council of State or the ordinary administrative courts as of 29 June 2027.
The arrangement also covers cases that remain pending before the Committee. Within the same deadline, a new application may also be submitted for cases in which one was originally filed but rejected by the Committee on formal grounds, as well as for cases that were called off or applications that were rejected where new evidence or case law has emerged, or where a final criminal court ruling has been issued.
The Out-of-Court Resolution Committee is not, however, the same as AADE’s Tax Dispute Resolution Directorate, nor as the electronic declaration of acceptance under Article 75. These are separate procedures, with different scope and conditions. For taxpayers, particularly small and medium-sized businesses, the key is to check in good time which procedure is available and which deadline still applies to their particular case.
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