Greece: Introduction of Deviation Limits for Pre-filled Income Tax Returns

Kelly Muniz
March 21, 2025

The Greek authorities have published Decision 1045/2025, implementing regulations under the Greek Tax Procedure Code regarding pre-filled income tax returns.

Particularly, the decision regulates the completion and submission of the Statement of Financial Data from Business Activity (Form E3) and the determination of taxable business results based on taxpayer data transmitted to the myDATA platform.

Since the 2023 tax year, Form E3 has been pre-filled based on data submitted to myDATA by taxpayers. However, from the 2024 tax year onwards, taxpayers may only modify these pre-filled amounts within certain limits.

Therefore, according to the new rules, a 30% deviation cap is established for revenue and expense data reported in Form E3, per tax year, in relation to the corresponding myDATA-reported values.

In addition to deviation limits, the Decision also regulates aspects such as the classification of income and expenses, the mandatory reconciliation of reported data with myDATA records, and the procedures for handling discrepancies or corrections in pre-filled amounts.

All entities subject to myDATA obligations that are required to submit Form E3 must comply with the decision, which applies to income tax returns from the 2024 tax year onward.

Pre-filled VAT Returns

Since 2022, Greece’s Independent Authority for Public Revenue (AADE) has been pre-filling VAT returns using data collected through the myDATA system.

As with Form E3, deviation limits were also initially set for discrepancies between VAT return data and the values submitted to myDATA. However, this limit has been phased out over time, and as of 1 January 2025, the permissible deviation limits for income and expenditure data per VAT tax period in relation to corresponding myDATA-reported values no longer exist.

It is expected that deviation limits for Form E3 may also be gradually reduced over time, following the trend seen with VAT returns. This underscores the growing importance of accurate and timely data transmission to the myDATA platform, as businesses will need to ensure that their reported figures closely align with the amounts declared to maintain compliance and avoid potential discrepancies.

For more information about the current state of play of pre-filled returns around the world, visit our Sovos dedicated webpage.

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Author

Kelly Muniz

Kelly Muniz is a Senior Regulatory Counsel at Sovos, specializing in global e-invoicing developments. Originally from Brazil and currently based in Stockholm, Kelly holds a Bachelor’s Degree in Law and worked as a licensed lawyer in her home country. She also earned a Master’s Degree in EU Business Law from Lund University in Sweden.
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