How Businesses Can Obtain Tax Certainty Before Entering into a Significant Transaction?
Most businesses are not concerned solely with the amount of tax they may have to pay. What concerns them even more is the possibility that a transaction considered tax-compliant today could be interpreted differently during a future tax audit.
Tax uncertainty has a direct impact on investments, corporate restructurings, mergers and acquisitions, international transactions, and overall business planning. The more complex a transaction becomes, the greater the need for clarity regarding its tax treatment.
This is precisely where the new framework of Tax Rulings comes into play.
Tax Rulings provide businesses, investors, and individuals with the opportunity to request an official and binding interpretation of tax legislation from the Independent Authority for Public Revenue (AADE) before a planned transaction takes place.
In simple terms, they allow taxpayers to understand in advance how the tax authorities are likely to view a specific transaction, reducing tax risk and increasing certainty when making important business decisions.
What Are Tax Rulings?
Law 5301/2026 introduced Article 9A into the Greek Tax Procedure Code, establishing the legal framework for requesting a Tax Ruling from the Greek tax administration.
A Tax Ruling applies to specific future facts and circumstances that have not yet occurred and aims to clarify in advance the tax treatment of a proposed transaction or business arrangement.
The framework applies to tax and customs matters where there is genuine uncertainty regarding the interpretation of the law. However, it does not cover cases already under dispute, nor does it apply to Advance Pricing Agreements (APAs) relating to transfer pricing methodologies.
Why Are Tax Rulings Important for Businesses?
Businesses can plan for a known tax cost. What is far more challenging is managing an uncertain tax risk.
A merger, demerger, business contribution, real estate investment, international structure, or digital business model can be significantly affected by how tax legislation is ultimately interpreted.
Tax Rulings help businesses:
- Reduce tax uncertainty and tax risk
- Strengthen investment confidence
- Improve corporate governance
- Make better-informed business decisions
- Minimize the likelihood of future tax disputes
Their value goes beyond tax compliance. They are increasingly becoming a strategic business tool that supports decision-making and risk management.
Considering a Tax Ruling for Your Business?
Tax Rulings represent a valuable mechanism for businesses and investors seeking greater certainty before implementing significant transactions or strategic initiatives.
The successful use of the process depends on proper preparation, accurate documentation of the facts, and a well-structured tax position supported by relevant legal and technical analysis.
At AFS, we assist businesses, investors, and corporate groups in evaluating, preparing, and managing Tax Ruling applications, helping them reduce tax risk and gain greater confidence in their business decisions.
Contact Our Team
If you are considering an investment, corporate restructuring, international transaction, or any business initiative involving significant tax considerations, our team can help you assess whether a Tax Ruling may be beneficial in your case. Complete the contact form and an AFS advisor will get in touch to discuss your business needs and explore the opportunities offered by the Tax Ruling framework.
