SUBJECT: Important new tax provisions of Law 5222/2025

With this note, we would like to briefly inform you about the most significant tax provisions introduced by Law 5222/2025, which was published in Government Gazette A’ 134 on July 28, 2025.

Tenfold increase of fines for transportation of goods without Dispatch Notes (Article 214)

1. Very strict fines are now imposed for the transportation of goods without a Dispatch Note, specifically:
   For a taxpayer transporting goods without the required supporting transport documents, a fine of five thousand (5,000) euros per tax audit is imposed if they are required to keep single-entry accounting records, and ten thousand (10,000) euros per tax audit if they are required to keep double-entry accounting records. In case of recurrence, a fine equal to double the amount of the initial violation is imposed, and in every subsequent recurrence, a fine equal to four times the amount of the initial violation is imposed.
2. Electronic invoicing (e-Invoicing) & incentives (Article 239)
   Electronic invoicing is extended to all transactions between businesses.
   Key points:
   • Obligation:
     • All businesses keeping books under the Greek Accounting Standards (EAS/ELP) must issue invoices electronically.
     • Applies to domestic transactions as well as exports to third countries (outside the EU).
     • Retail transactions with private individuals are temporarily excluded (covered by cash registers / POS).
   • Effective date:
     • The exact start date of application, as well as any exemptions or transitional periods, will be determined by a specific decision of the Ministry of Finance and the Independent Authority for Public Revenue (AADE).
   • Incentives for early adoption (before mandatory application for all):
     • Tax deductions or faster VAT refunds for businesses that adopt e-Invoicing early.
     • Exemption from certain reporting/filing obligations (e.g., MYF declarations).
   • Penalties:
     • Failure to issue or transmit invoices → fines up to €10,000 per audit (depending on the accounting system and number of violations).
     • Additional penalties in case of recurrence.
3. Mandatory bank payment of rents (Article 210)
   The new Law introduces a clear obligation that all rents (both commercial and private) must be paid via a bank account (or through an electronic payment method processed through the banking system).
   This practically means that:
   • The lessor (property owner), whether an individual or a business/company, loses the right to deduct tax expenses (repairs, maintenance, property costs) if they accept rent payments outside the banking system (cash).
   • The lessee (tenant) cannot benefit from housing allowances or other tax reliefs (e.g., deduction for primary residence) if the payment has not been made through a bank.
   • Payment is permitted via e-banking, standing order, or deposit to a bank account.
   • A private agreement or cash receipt is not sufficient — there must be a record of a banking transaction.

Therefore, the tax benefit from property is now mandatorily linked to the transparency of the payment.