Impact of Greek Tax Reform on E-Invoicing

Joanna Hysi
August 27, 2020

With the 1 October go-live date for myDATA, the first Greek implementation of Continuous Transaction Controls (CTC), fast approaching, legal clarity around the broader tax reform should ideally be close to completion. Greece’s tax reform is expected to not only cover CTC reporting but also e-invoicing.  So far, however, we have only seen fragmented documentation with no clear mandate defined or communicated for e-invoicing. This creates uncertainty with just a few months before the myDATA roll-out.

Connected but independent frameworks

The fragmented e-invoicing documentation was released at the same time as the myDATA documentation. This created the notion that the two legal frameworks were interconnected in a way that the e-invoicing documentation would only apply to the myDATA implementation.  Part of documentation covered e-invoicing through accredited service providers, introduced in February in Decision No 1035/2020, which, according to myDATA legislation is also one of the data transmission methods to the myDATA platform.  Other methods include reporting from the ERP or online cash registers. However, as further e-invoicing legislation has been published, i.e. e-invoicing incentives for taxpayers choosing to use accredited service providers for their e-invoicing processes, it‘s clear that the two frameworks are – or rather were intended to be – independent.

No immediate change to e-invoicing

It’s important to remember that although the IAPR clearly plans to embrace CTC e-invoicing in the future, for the time being the existing post audit e-invoicing rules remain the same. The myDATA scheme, rolling out on 1 October, doesn’t impact e-invoicing in Greece. Taxpayers can continue issuing paper invoices or electronically, meet the integrity and authenticity requirements by any methods accepted in the VAT Directive (digital signatures, business controls establishing an audit trail between an invoice and supply (BCAT) or EDI with an interchange agreement based on the European Commission 1994 Recommendation), outsource and automate their B2B e-invoicing processes through their chosen service provider, as long as they report their data to the myDATA platform through their ERP.

Businesses that have already automated their e-invoicing businesses processes in Greece, e.g. procure to pay, order to cash, do not need to stop even if their vendor is not accredited. Similarly, vendors that offer automated e-invoicing processes in Greece, can keep doing so without having to become accredited.

A key takeaway for businesses and service providers who operate in Greece is that post audit e-invoicing is still possible and compliance with local post audit legislation is required. However, since the IAPR has already taken steps towards embracing some type of CTC e-invoicing, businesses should expect that further information is expected in the coming months providing welcome clarity on the shape and form of such a clearance system.

Take Action

Sovos has more than a decade of experience keeping clients up to date with e-invoicing mandates all over the world.

Sign up for Email Updates

Stay up to date with the latest tax and compliance updates that may impact your business.


Joanna Hysi

Joanna is a Senior Regulatory Counsel at Sovos. Based in Stockholm and originally from Greece, Joanna’s background is in commercial and corporate law with research focus on EU law and financial innovation. Joanna earned her degree in Law in Greece and her masters in Commercial and Corporate from London School of Economics and Political Science (LSE) in London.
Share This Post

North America ShipCompliant
May 25, 2023
Out-of-State Breweries Gain Self Distribution, DtC Rights in Oregon

Under a settlement agreement, breweries located outside of Oregon now have more options for selling into the Beaver State, including direct-to-consumer (DtC) shipping and self-distribution to retailers. The settlement arose out of a lawsuit filed by a group of Washington breweries last year challenging Oregon laws that limited beer self-distribution to in-state breweries and DtC […]

EMEA VAT & Fiscal Reporting
May 24, 2023
VAT and Art: What you need to know

Significant inflation increases have impacted most of the world’s economies, with the UK still above 10% in 2023. This increase means a reduction in the purchasing power of consumers. Together with increases in the cost of raw materials, this has created uncertainty regarding growth of entire industrial departments and reduced profit margins for companies. The […]

North America ShipCompliant
May 23, 2023
Top 5 Myths Surrounding Retailer Direct-to-Consumer Wine Shipping

By Tom Wark, Executive Director, National Association of Wine Retailers Politics breed myths. This has always been the case as politics is, at its most fundamental, a form of storytelling. So it should be no surprise that myths have arisen as various elements of the wine industry have fought against consumers and specialty wine retailer seeking […]

May 23, 2023
IPT: Location of Risk and Territoriality

Much of the discussion on the Location of Risk triggering a country’s entitlement to levy insurance premium tax (IPT) and parafiscal charges focuses on the rules for different types of insurance. European Union (EU) Directive 2009/138/EC (Solvency II) set out these rules. However, a related topic of growing importance in this area concerns territoriality, i.e. […]

Asia Pacific E-Invoicing Compliance
May 23, 2023
Japan: New e-Invoice Retention Requirements

Japan’s new e-invoice retention requirements are part of the country’s latest Electronic Record Retention Law (ERRL) reform. Along with measures such as the Qualified Invoice System (QIS) and the possibility to issue and send invoices electronically via PEPPOL, Japan is implementing different indirect tax control measures, seeking to reduce tax evasion and promote digital transformation. […]