Filenews 6 January 2026 - by Eleftheria Paizanou
The Tax Department has acquired new weapons from the 1st of January new year to strengthen tax compliance and collectability of the state.
In the context of the tax reform, the possibility of sealing (suspension of operations) of businesses with tax pending issues and the freezing of shares for tax debts over €100,000 have been implemented.
The measures were taken because, according to the final texts of the laws approved by the Plenary Session of the Parliament and published in the Official Gazette of the Republic, the traditional tax mechanisms had proven to be inadequate to meet the needs of the state and the citizens, while with the reform of the tax system, it responds with greater flexibility, fairness and efficiency to modern economic and social requirements.
The sealing of companies and the freezing of shares, according to the new laws, will be done as follows:
Business sealing
The Tax Commissioner can now suspend the operation of a business and seal its premises, in the event that an owner fails to submit two tax returns or at least twelve monthly tax and contribution withholding returns or at least three VAT tax returns, on or after January 1, 2027.
Essentially, by extending compliance until 2027, taxpayers are given room to comply.
In addition, based on the new legal framework, the Tax Commissioner can put a closure on a business, when the owner fails to pay the required tax, according to the tax returns, withholding declarations or due amounts of value added tax and provided that the total amount due, including charges, exceeds €20,000.
At the same time, in the case of a tax assessment by the Tax Commissioner for the calculation of the tax in the total amount due, the deadlines for administrative or judicial dispute must have expired or in case of a timely dispute, all administrative and judicial dispute procedures must have been exhausted.
At the same time, the measure will be applied, in the event that the taxpayer did not issue the prescribed invoices and receipts or issued inaccurate invoices or receipts. In addition, it hinders the conduct of tax audits. It is worth mentioning that the suspension of the operation of businesses and the closure of premises cannot exceed ten days.
Three warnings
A prerequisite for the Tax Commissioner to take the relevant decisions is the sending of three notices to the owner or the person who carries on the business, by double-registered letter to the business or to the registered office of the legal entity associated with the business or by posting it in a visible part of the business.
Taxpayers will have 25 days to comply with their obligations. From the sending of the first notice of intention to seal the premises, taxpayers have ten days to do so.
Then, in case the taxpayer still does not comply, then a second notice is sent to him with another ten days. If there is no compliance this time either, then a third notice is forwarded and at the same time the tax collector invites the taxpayer to submit his views in writing within five days after sending the third letter.
According to the legislation, if taxpayers do not comply with their tax obligations, then the operation of the business will be suspended and the premises will be sealed. It is worth noting that the Tax Commissioner should indicate in the decision the exact time of enforcement and serve it immediately to the interested party. In fact, if he is not located, then the decision will be posted in a prominent place in the business.
The police will also assist in the execution of the decision, while a tape will be placed at the entrance of the business stating in Greek and English the name of the Tax Department and the dates on which the premises were sealed. The decision of the Registrar to seal the businesses will come into force from the day of publication in the Official Gazette of the Republic.
Anyone who violates the suspension of the business commits a criminal offence and in case of conviction is subject to two years or a fine of €30,000 or both. Any judicial challenge to the suspension of the operation of the business does not suspend the obligation of the person or the business to comply with its obligations and the right of the Registrar to exercise his powers to ensure the compliance of the person or the business with their obligations and to take measures for the collection of the taxes due.
Stock Commitment
The blocking of the shares will be made for tax debts of €100,000 for a period of more than 30 days from the date they become payable, excluding taxes that have not expired, debts paid in instalments, or if the Council of Ministers decides to forgive or write off or a process is in progress or security has been provided for the payment of the tax.
According to the law, the Tax Commissioner may proceed with the freezing of shares of legal entities worth up to twice the tax due plus interest and charges. It is noted that the Tax Commissioner, before submitting a relevant note to the Registrar of Companies, informs the person by written notice of his intention to submit the note, informing him of the reasons for which he intends to act and granting the right to submit representations within 30 days from the date of notification of the notification.
The blocking of the shares will essentially be a guarantee for the payment of the tax due, upon submission to the Registrar of Companies of the relevant note. The filing of the note constitutes an entry of a commitment on the shares, which cannot be transferred for the duration of the commitment. The Registrar, immediately after the registration of a commitment, serves a written notice on the person. In the case of a freezing registration, a person has the right to apply to the Court for a decision to cancel the freezing registration.
If the Court issues a decision to cancel the freezing of the shares, the Registrar of Taxation, within fifteen days from the day of the issuance of the decision, informs the Registrar of Companies of the withdrawal of the registration of a commitment.
