Tax offenses

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.