Thousands of Tax Cases Remain Pending

Greece’s administrative court system is struggling under the weight of approximately 13,000 pending tax and customs cases, with delays stretching two to three years per case, according to the latest government data. The massive backlog in tax court cases is imposing significant financial burdens on both the Greek state and individual claimants, as citizens and businesses wait years for their disputes to be resolved.

The Ministry of Justice reports that 4,613 tax cases are currently awaiting decisions in administrative courts of appeal, though only 1,924 have been assigned future hearing dates. Additionally, 8,302 cases remain pending in administrative courts of first instance, with just 3,991 having received hearing numbers, leaving thousands in legal limbo with no clear timeline for resolution.

Failed Reforms and Incomplete Solutions

During Greece’s economic crisis and subsequent bailout period, lawmakers introduced tax arbitration mechanisms designed to accelerate dispute resolution and reduce pressure on administrative courts. However, the institution never became operational because authorities failed to establish the required infrastructure and did not issue the necessary regulatory framework for implementation.

The tax arbitration law remained dormant while new provisions were introduced in 2013, creating the Dispute Resolution Directorate within the Independent Authority for Public Revenue (AADE). Under this framework, taxpayers and businesses must first navigate the resolution directorate before pursuing appeals in administrative courts, a requirement that has provided modest relief but has not eliminated the fundamental backlog issues.

Committee Reopening Offers Limited Hope

In response to ongoing challenges, the government established the Committee for the Out-of-Court Resolution of Tax Disputes in 2020. The committee primarily addresses cases involving disputed business fines, statute of limitations questions, and potential errors made by tax authorities. Despite having an original expiration date, the committee is scheduled to reopen next Friday, the ministry said.

The persistent delays in tax court cases create substantial economic consequences for Greece. Businesses facing unresolved tax disputes struggle with financial uncertainty, potentially affecting investment decisions and economic planning. Meanwhile, the state loses potential revenue collection opportunities while dedicating resources to maintaining the backlogged court system.

Systemic Challenges in Tax Court Cases

The Greek administrative court system’s inability to process tax and customs disputes efficiently reflects broader structural problems within the judicial framework. The gap between pending cases and scheduled hearings—with fewer than half of all pending cases having assigned dates—illustrates the magnitude of the resource shortage facing these specialized courts.

Legal experts point to the layered approach of multiple dispute resolution mechanisms as both a solution and a complication. While the Dispute Resolution Directorate and the Out-of-Court Resolution Committee were intended to filter cases and reduce court filings, the existence of parallel systems may contribute to procedural confusion and administrative complexity.

The incomplete implementation of tax arbitration remains particularly significant, as this mechanism was specifically designed during the bailout era to modernize Greece’s approach to fiscal disputes. The failure to operationalize this reform represents a missed opportunity to address systemic delays that have only worsened over subsequent years.

Authorities have not confirmed whether additional judicial appointments or administrative reforms are planned to address the backlog of pending tax court cases. The reopening of the Out-of-Court Resolution Committee next Friday may provide temporary relief, though the long-term effectiveness of this measure in reducing the 13,000-case backlog remains uncertain without comprehensive structural reforms to the administrative court system.