Greece’s highest administrative court has made a major decision that could help many taxpayers. In a recent ruling (Decision 366/2025), the Council of State said that companies fined for using fake invoices can still get reduced penalties—even if they haven’t met all the strict legal conditions usually required.
The case involved a company from Volos that was fined for accepting fake invoices from a related company in Bulgaria. Normally, under Greek law, to get a lighter penalty, a company has to fully accept the charges and give up its right to appeal. But a lower court decided this was unfair and reduced the fine anyway, saying those rules went against basic legal rights.
Greece’s tax authority, AADE, appealed the decision. But the Council of State rejected the appeal, agreeing with the lower court. It said that refusing a lighter penalty just because of formal rules—like forcing someone to give up their right to challenge a fine—is not fair or legal under European law.
This decision means that Greek tax authorities and courts must apply lighter penalties when the law allows it, even if some conditions aren't met. The court made it clear that rules created just to make tax collection easier cannot take away people’s right to justice.
The ruling is expected to affect many open tax cases, possibly leading to reduced fines for other businesses as well. In simple terms, it’s a win for taxpayers and a reminder that fairness and legal rights must come before red tape.
