Tax offences and tax evasion in Greece
A tax offence exists where taxes are intentionally not assessed, not fully assessed, or not assessed on time, because the person liable to pay tax, to file a return, or to make a declaration fails to comply with their obligations towards the tax authorities. The legal basis is essentially Art. 66 of the Tax Procedure Code (Law 4174/2013).
Current Value Thresholds and Sentencing Ranges
- Concealment of taxable income or assets (to avoid income tax, the uniform property tax ENFIA, or the special property tax EFA): imprisonment of at least two years, where the evaded tax exceeds €100,000 per tax year and type of tax.
- Non-payment, incorrect payment, refund, offsetting, or withholding of taxes owed: imprisonment of at least two years, where the amount exceeds €50,000 for VAT, or €100,000 for other withheld taxes and charges, per tax year.
- Issuing, accepting, or falsifying sham or falsified tax documents: imprisonment of at least three months, regardless of whether taxes were actually evaded as a result – unless the documents served to commit one of the offences named above, in which case punishment follows only for that principal offence.
In determining the sentence, particular account is taken of the amount concealed or not paid over, as well as the duration of the concealment; the use of special concealment techniques is treated as an aggravating factor.
Non-Payment of Debts Due to the State
The non-payment of assessed debts to the state and the public sector is separately regulated (Art. 25 of Law 1882/1990). A person who fails to settle such debts for more than four months is punished with imprisonment of at least one year, where the total debt – including interest and surcharges – exceeds €100,000; below this threshold, no offence exists. Law 5193/2025 has also significantly expanded the possibilities for suspension: for a person who brings their debts into an instalment payment arrangement or benefits from a suspension of enforcement, criminal prosecution is suspended for the duration of the arrangement, or enforcement of a sentence already imposed is deferred.
In the case of tax offences committed by legal entities, criminal prosecution is directed against the chairman of the board of directors or the managing director of a stock corporation, the partners with unlimited personal liability of a general partnership, the managing director of a limited partnership or GmbH, and the manager, authorised representative, or agent of a foreign business establishment.
Examples from Practice
- accepting sham invoices,
- recording fictitious invoices to simulate higher expenses and thereby a lower tax burden,
- submitting inflated invoices in order to obtain higher subsidies, and
- selling goods to foreign companies by means of sham invoices, with subsequent resale to non-existent Greek companies, in order to fraudulently obtain input tax deductions in intra-Community trade.
FAQ
Tax evasion is a criminal offence if taxes are intentionally not assessed, not fully assessed or not assessed on time because the taxpayer fails to comply with his or her obligations towards the tax authorities – for example by not filing a return, filing an inaccurate return or recording fictitious expenses. The legal basis is Art. 66 of the Tax Procedure Code (Law 4987/2022, previously Law 4174/2013).
The offence is punishable with imprisonment of at least two years if, per tax year and type of tax:
• the tax on concealed income or assets (income tax, ENFIA, special property tax EFA) exceeds €100,000, or
• unpaid, incorrectly paid, refunded, offset or withheld taxes exceed €50,000 for VAT or €100,000 for other taxes, fees and contributions.
If the amount evaded exceeds €100,000 for VAT or €150,000 for other taxes, fees and contributions per year, the offence is punishable as a felony with κάθειρξη (incarceration).
The court takes into account in particular the amount concealed or not paid and the duration of the concealment. The use of special concealment techniques is an aggravating factor.
Yes. Issuing, accepting or falsifying fictitious or falsified tax documents is punishable with imprisonment of at least three months – regardless of whether tax was actually evaded. If the documents were used to commit tax evasion, the offender is punished only for the tax evasion.
Yes. For fictitious invoices relating to transactions that do not exist in whole or in part:
• total value over €75,000: imprisonment of at least one year,
• total value over €200,000: imprisonment of at least one year or incarceration of up to six years.
• accepting sham invoices,
• recording fictitious invoices to simulate higher expenses and thus a lower tax burden,
• submitting inflated invoices to obtain higher subsidies,
• carousel fraud: selling goods to foreign companies by means of sham invoices and reselling them to non-existent Greek companies in order to obtain input tax deductions in intra-Community trade.
Yes, above certain thresholds. Under Art. 25 of Law 1882/1990, a person who fails to pay debts assessed by the tax authorities or other public bodies for more than four months is punishable:
• with imprisonment of at least one year if the total debt – including interest and surcharges – exceeds €100,000,
• with imprisonment of at least three years if it exceeds €200,000.
Below €100,000, there is no criminal offence.
Yes. A person who brings the debts into an instalment arrangement or benefits from a suspension of enforcement is not prosecuted for the duration of the arrangement, or the enforcement of a sentence already imposed is deferred. The amendments of 2025 (Law 5193/2025) have significantly extended these options. Full payment of the debt extinguishes criminal liability; if the arrangement is lost, the public prosecutor is informed.
Criminal liability is borne by the natural persons responsible, in particular:
• in a stock corporation (AE): the chairman of the board of directors, the managing director and other persons with management authority,
• in a general or limited partnership: the partners with unlimited liability and the managers,
• in a limited liability company (EPE) or IKE: the managers,
• in a foreign company's branch: its manager, authorised representative or agent in Greece.
Contact a lawyer experienced in tax criminal law as early as possible – ideally already during the tax audit. Early regularisation of debts, for example through an instalment arrangement, can avoid or suspend criminal prosecution.
As of June 2026. All information on these pages is provided without guarantee or liability.