## Tax Administration Reform in Greece: Outcomes and Lessons (2010–25) — insea2026003

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### Executive Summary and Background
- Objective: document and analyze Greece’s tax administration reform experience over 2010–25, focusing on reform sequencing, institutional development, and interaction between legal, organizational, HR, and digital reforms.
- Approach: structured, longitudinal account (not causal attribution) using internal IMF documentation, technical assistance experience, performance indicators, and international benchmarks.
- Crisis context and macro path:
  - Prolonged economic contraction during 2009–13; gradual recovery beginning in 2014–15; temporary disruption in 2020 from COVID-19; strong rebound thereafter; by 2023–25 Greece returned to sustained positive growth.
  - Primary balance improved by more than 15 percentage points of GDP between 2009 and 2024, reaching a historic surplus in 2024.
  - Revenue‑to‑GDP ratio rose from 39.4 percent in 2009 to 49.3 percent in 2024.
  - Public debt rose from about 111 percent of GDP in 2008 to 128 percent in 2009, reached crisis-era peaks thereafter, and declined substantially by 2025 supported by primary surpluses above 2 percent of GDP, robust growth, and strong revenue performance.
- Two-step revenue turnaround:
  - Initial crisis period: front‑loaded tax policy measures and focused administration on high-risk sectors to stabilize revenues.
  - Later period: structural and institutional reforms and digital transformation to broaden the tax base and improve compliance.

### Reform Pillars, Phases, and Sequencing
- Three interlinked reform phases:
  - Phase 1 (2010–12): stabilizing revenues via targeted enforcement actions and early digital initiatives.
  - Phase 2 (2013–17): structural and institutional transformation, legal modernization, organizational consolidation, and establishment of the Independent Authority for Public Revenue (IAPR).
  - Phase 3 (2018–25): ambitious digital transformation centered on near‑real‑time reporting, expanded use of third‑party data (UTD), advanced analytics, and increasingly automated compliance management.
- Design principles emphasized:
  - Sequencing: legal and institutional foundations first to improve later digital investments’ effectiveness.
  - Phased implementation to allow learning and course correction.
  - Integration across governance, organizational, legal, HR, and digital streams.

### Box 1 — Key Tax Policy Reforms (2010–19)
- Scope: VAT, personal income tax (PIT), corporate income tax (CIT), property tax, and excise duties.
- Personal Income Tax (PIT):
  - New Income Tax Code (2013/effective 2014) simplified PIT structure.
  - Top marginal PIT rate increased from 40 percent to 45 percent (for annual taxable income over 40,000 €).
- Corporate Income Tax (CIT):
  - Statutory CIT rate: increased from 20 percent to 26 percent in 2013; increased to 29 percent in 2015; reduced to 24 percent in 2019.
  - Withholding tax on dividends reduced from 10 percent to 5 percent in 2019.
- Indirect Taxes:
  - Standard VAT rate increased from 19 percent to 24 percent between 2010 and 2016.
- Property Taxes:
  - 2011: Emergency Special Property Charge collected through electricity bills.
  - 2014: Unified Real Estate Property Tax introduced.
  - 2013 (effective 2014): Property transfer tax reduced from 10 percent to 3 percent.
- Immediate post-crisis reforms and digitalization:
  - VAT Automated Filing and Payment System implemented in May 2011.
  - TAXISnet upgrades; mandatory electronic VAT filing established in 2011.
  - On-time VAT filing rose from about 65–70 percent in 2010–11 to over 96 percent by 2014.

### Introduction of the Tax Procedure Code (TPC) and Institutional Reform
- TPC enacted January 2014:
  - Consolidated procedural provisions; phased implementation requiring secondary legislation and enabling measures.
  - By March 2016, several supporting measures (automated estimated assessments for non-filers, tax rulings, electronic notifications) remained pending.
- Dispute Resolution Unit established September 2013.
- IAPR establishment and governance:
  - IAPR began operations on January 1, 2017 as an operationally and financially autonomous authority.
  - Article 19(3) of Law 4389/2016 established a binding budgetary safety net.
  - Operational budgets at IAPR increased from €411 million in 2017 to €507 million in 2025—an average annual growth of approximately 3 percent—although net staffing levels remained stable or declined throughout much of the reform period.
- Merit-based leadership appointments:
  - Law 4389/2016 set open competition and independent Selection Committee procedures for Management Board and Governor appointments, reducing discretionary appointments and strengthening independence.

### Reform Blueprint, Program Scale, and Financing (2018–25)
- Reform Blueprints:
  - December 2017 Blueprint covering 2018–2020 across five components: comprehensive service, upgraded enforcement, people, technology, and infrastructure.
  - December 2020 revised Blueprint covering 2021–2025 with ambitious IT, HR, organization design, business processes, and service delivery agenda.
- Financing:
  - By 2023, 19 IAPR projects had EC Recovery and Resilience Fund (RRF) financing of €290 million contingent on milestones through Q4 2025.
  - IAPR implementing an additional 31 reform projects tied to other financing sources between now and 2027.

### Digital Transformation and myDATA (2018–25)
- Shift to near-real-time, analytics-based administration; alignment with Ministry of Digital Governance after 2019.
- Key digital milestones by year:
  - 2019: BI and DW modernization
  - 2020: Digital pandemic responses; launch of myDATA
  - 2021: myAADE digital portal platform
  - 2022: Appodixi app; prefilling of VAT begins in December 2022
  - 2023: Prefilling of CIT; developing AuditLIVEAADE; mandatory e-invoicing for B2G
  - 2024–25: Mandatory POS connection to cash register; mandatory reconciliation of sales and expenses
- myAADE portal (September 2021): consolidated access to AADE digital services and phased out myTAXISnet.
- myDATA platform:
  - Launched 2020; mandatory in November 2021 with scope expanded; real-time transmission of invoices and accounting entries became mandatory from 2024.
  - myDATA supports B2B, B2C, and B2G; enforces VAT returns to match uploaded myDATA data; penalties for non-compliance.
  - All businesses required to transmit accounting data electronically; multiple submission channels available.
  - Functional features include QR codes for invoice verification and strict reconciliation rules for VAT returns.

### Box 2 — myDATA Transaction Types and E-invoicing Rollout
- myDATA transaction types include: Sales invoice; Receipt for retail sales; Invoice for services rendered; Credit notes for retail sales; Acquisition title; Contract (revenue or expense); Credit notes for invoices; Special record (receipt); Records for self-supply—private use; Personnel expenses; Transport document; Depreciation; Receipt for services rendered; Other adjusting entries for revenues/expenses.
- E-invoicing rollout and mandates:
  - B2G e-invoicing obligation began September 2023 and fully implemented by January 2025.
  - July 2025: EU approved mandatory B2B e-invoicing for all domestic transactions.
  - From January 2024, all retail businesses required to use POS terminals connected to cash registers; mandatory POS connections extended in May 2024.
  - Initial pilots showed only 50 percent of businesses ready to provide live data by mandated start date.
  - Transaction volume estimated at 500 million per year.
  - Penalties apply for non-compliance with POS and invoice-reporting obligations.

### Business Intelligence (BI), Data Warehouse (DW), and Digital Audit Tools
- DW installed in 2014 was initially underused due to incomplete data and unclear requirements.
- Major BI modernization launched May 2019 with RRF backing; external consultants developed BI road map.
- Pilot projects (e.g., fuel tax monitoring) shaped full BI system using Corporate Information Factory model.
- DW being expanded to integrate real-time myDATA data for advanced analytics and CRM.
- January 2024: automated VAT refund risk assessment software deployed, reducing manual audits and accelerating refund processing.
- Digital audit tools:
  - Appodixi app (2022) for QR-code receipt verification and anonymous reporting.
  - AuditLIVEAADE (August 2023) for auditors’ real-time access to taxpayers’ financial profiles.
  - Bankapp (January 2024) automates assessment of wealth increase.

### HR Reforms and Professionalization
- HR framework under IAPR Law allowed bespoke staffing, mobility, promotions, and remuneration deviations from standard public sector rules.
- Measures and milestones:
  - Bonus incentive program introduced December 2017.
  - Tax and Customs Academy launched February 2018.
  - Staff appraisal program implemented July 2019.
  - Pay and grading reform enacted in 2021.
  - By 2023, audit and collection centralized into six national audit centers and two debt collection centers.
- Staffing dynamics:
  - Number of tax offices reduced from 288 to 119 between August 2012 and October 2013 (15 months).
  - Headquarters staff (tax and customs) reached 1,351—approximately 12 percent of total staff.
  - Staffing levels overall declined from 7,627 in February 2016 to 7,254 in September 2021.
  - Net staffing levels remained broadly flat or declined after 2010, constraining capacity despite productivity gains.

### Reform Impact, Performance Indicators, and Key Statistics
- Tax-to-GDP ratio: 20.5 percent in 2009, climbing steadily to over 28 percent in 2025.
- VAT compliance gap: decreased from 30 percent in 2011 to 9 percent in 2024. The overall reduction in the compliance gap from 2011 to 2024 is 21 percent.
- VAT e-filing: reached 100 percent since 2022.
- CIT e-filing: attained 99.9 percent from 2021 onward.
- E-payment adoption: rose from 86.6 percent in 2018 to 99.2 percent in 2023.
  - Notable increase from 90.4 percent in 2021 to 98.8 percent in 2022.
- Tax arrears (Closing Stock Arrears at Year End as Percent of Total Revenue Collected):
  - 2018: 213.1
  - 2019: 191.5
  - 2020: 228.3
  - 2021: 203.0
  - 2022: 190.6
  - 2023: 159.0
- Tax arrears performance by type:
  - CIT arrear rate decreased from 893.1 percent in 2020 to 233.1 percent in 2023.
- Operational Strength Index (OSI):
  - OSI (aggregate of 193 ISORA survey questions across nine sub-indices) showed notable improvements since 2015, especially from 2017 onward.
  - OSI sub-indices with significant progress: UTD, AUT, HRM; six areas—CRM, UTD, AUT, large taxpayer office and HNWI, tax enforcement, and HRM—outperformed advanced economies and EUR in 2022.
- TADAT assessments:
  - Comparison over five years shows significant progress; five out of thirty-two indicators meet international good practices.
  - Noted improvements: POA 3-10 (scope of initiatives to reduce taxpayer compliance costs), POA 5-17 (timeliness of payments), POA 6-20 (use of large-scale data-matching systems), POA 8-27 (adequacy of tax revenue accounting), POA 9-29 (internal assurance mechanisms).
- Refunds and processing:
  - Only 23 percent of VAT refunds were processed within 30 days as of the 2023 TADAT assessment despite automated risk assessment software deployment.

### Implementation Challenges and Constraints
- Key constraints:
  - Resistance to organizational change; consolidation generated uncertainty.
  - Staffing and budget limitations; declines in net staffing constrained capacity.
  - Early underuse of BI/DW and incomplete data coverage; unclear business ownership of data initiatives.
  - Lag in secondary legislation delayed full operationalization of TPC provisions.
  - Dispute resolution bottlenecks, especially for HNWI cases.
  - Project and change management weaknesses; overly centralized decision making slowed strategic activities.
  - Transaction-level reporting commenced later than planned; flexible reporting channels not universally adopted.
- Operational observations:
  - Audit selection procedures revised late; high share of targeted cases concerned older tax years, limiting impact on current compliance.
  - DW installed in 2014 underused; major BI infrastructure projects remained unfinished by 2021.
  - Initial pilots revealed readiness gaps (50 percent readiness in some sectors for live data).
  - Large legacy of long-aged and low-collectability debt remains; significant share of outstanding arrears unlikely to be fully recoverable.

### Role and Chronology of IMF Capacity Development (CD) Support
- IMF CD timeline highlights:
  - 2010 — Anti-evasion plan design.
  - 2011–15 — Strategic plan development and performance benchmarks.
  - 2013–14 — PMO establishment and governance support.
  - 2014–17 — Audit and collection strategies, HR reforms support.
  - 2018–20 — Reform blueprint drafting, IT modernization assistance.
  - 2021–23 — BI and risk management frameworks, training programs.
  - 2024–25 — Monitoring and implementation support for digital reforms such as myDATA.
- External financing and CD (IMF and European partners) played an important role in sustaining reform continuity and supporting large-scale digital investments.

### Lessons Learned and Strategic Implications
- Governance and autonomy:
  - Establishment of IAPR anchored credibility and enabled HR, risk management, and digital advances.
- Sequencing matters:
  - Legal and institutional foundations (e.g., TPC in 2014) should precede major digital investments to improve effectiveness.
- Sustained investments required:
  - Continued investment in analytics, BI/DW, AI-enabled tools, human capital, and change management is essential to translate technology into compliance and service gains.
- Reform design and implementation:
  - Phased, cumulative, and iterative reforms allow learning and course correction.
  - Change management and organizational development need to accompany technical CD to overcome resistance.
- Funding and CD models:
  - Innovative funding (RRF and other sources), performance-based financing, and donor coordination can sustain reform momentum.
- Service orientation:
  - Simplified procedures, pre-filled declarations, and perceived fairness and accessibility reinforce voluntary compliance.

### Strategic Priorities Going Forward
- Consolidation and sustainability of reforms rather than new launches.
- Systematic strengthening of data analytics and selective, responsible use of artificial intelligence (AI), fully integrated into CRM by design.
- Embed analytical and AI-enabled tools into core CRM workflows for risk segmentation, audit selection, case treatment, dispute resolution, and debt collection.
- Continued investment in skills development, leadership, and performance management through the Tax and Customs Academy of the IAPR.
- Maintain a taxpayer-centric approach with simplified procedures and pre-filled declarations.
- Disciplined sequencing and realistic implementation planning to align ambitions with institutional capacity and fiscal constraints, progressing toward Tax Administration 3.0 (OECD 2020).

*Tax Administration Reform in Greece: Outcomes and Lessons (2010–25), April 2026 (IMF Note).*

### Executive Summary ......................................................................................................

### Executive Summary

### Introduction
- Objective: document and analyze Greece’s tax administration reform experience over 2010–25, focusing on reform sequencing, institutional development, and interaction between legal, organizational, HR, and digital reforms.
- Approach: structured, longitudinal account (not causal attribution of individual measures) using internal IMF documentation, technical assistance experience, performance indicators, and international benchmarks.
- Scope: reforms launched after a severe economic and fiscal crisis to transform crisis-driven stabilization measures into a mature, digitally enabled, and increasingly autonomous tax administration.

### Background
- Crisis context and macro path:
  - Prolonged economic contraction during 2009–13, gradual recovery beginning in 2014–15, temporary disruption in 2020 from COVID-19, strong rebound thereafter; by 2023–25 Greece returned to sustained positive growth.
  - Primary balance improved by more than 15 percentage points of GDP between 2009 and 2024, reaching a historic surplus in 2024.
  - Revenue‑to‑GDP ratio rose from 39.4 percent in 2009 to 49.3 percent in 2024.
  - Public debt rose from about 111 percent of GDP in 2008 to 128 percent in 2009, reached crisis-era peaks thereafter, and declined substantially by 2025 supported by primary surpluses above 2 percent of GDP, robust growth, and strong revenue performance.
- Two-step revenue turnaround:
  - Initial crisis period: stabilizing revenues quickly under acute financing constraints using front‑loaded tax policy measures and focused administration on high-risk sectors.
  - Later period: emphasis on structural and institutional reforms and digital transformation to broaden the tax base and improve compliance.

### Tax Administration Reform Pillars and Sequencing
- Three interlinked reform phases:
  - Phase 1 (2010–12): stabilizing revenues via targeted enforcement actions and early digital initiatives.
  - Phase 2 (2013–17): structural and institutional transformation, legal modernization, organizational consolidation, and establishment of the Independent Authority for Public Revenue (IAPR) to strengthen operational autonomy, accountability, and strategic management.
  - Phase 3 (2018–25): ambitious digital transformation centered on near‑real‑time reporting, expanded use of third‑party data (UTD), advanced analytics, and increasingly automated compliance management.
- Reform design principles highlighted:
  - Sequencing: legal and institutional foundations first to enhance effectiveness of later digitalization.
  - Phased implementation to allow learning and course correction.
  - Integration across governance, organizational, legal, HR, and digital streams.

### Reform Impact and Outcomes
- Aggregate performance improvements:
  - Sustained increases in the tax-to-GDP ratio over time.
  - Significant improvements in compliance outcomes, notably a sharp reduction in the value-added tax compliance gap.
  - Operational improvements in filing and payment compliance, risk‑based audit selection, and service delivery.
  - By the early 2020s, Greece’s tax administration compared favorably with international benchmarks across several core dimensions of operational strength.
- Mechanisms of impact:
  - Data matching, compliance cost reduction, and dispute resolution improvements were closely associated with stronger compliance outcomes.
  - Progressive digitalization (near‑real‑time transaction reporting and data-driven compliance) supported more automated and targeted enforcement.

### Reform Implementation Challenges and Role of Capacity Development (CD)
- Key implementation constraints:
  - Resistance to organizational change.
  - Staffing and budget limitations.
  - Early underuse of business intelligence tools.
- Requirements to sustain progress:
  - Sustained political commitment and iterative reform design.
  - Close coordination across governance, organizational, legal, and digital reform streams.
  - Continued investment in analytics, human capital, and change management.
- Role of external support:
  - External financing and capacity development support—particularly from the IMF and European partners—played an important role in sustaining reform continuity and supporting large-scale digital investments.

### Lessons Learned and Strategic Implications
- Governance and autonomy reforms (e.g., establishment of IAPR) were critical to anchor credibility and enable subsequent operational and digital advances.
- Reform sequencing matters: establishing legal and institutional foundations before major digital investments improves effectiveness.
- Sustained investment in analytics, human capital, and change management is essential to translate technological innovation into improved compliance and service delivery.
- Reforms are cumulative and iterative; phased implementation allows learning and course correction.
- While country circumstances differ, these lessons provide relevant insights for jurisdictions seeking to modernize tax administration and strengthen domestic revenue mobilization over the medium term.

### Looking Ahead
- Continued focus areas implied by the reform experience include:
  - Deepening data-driven compliance and analytics capabilities.
  - Strengthening HR and professionalization to sustain digital and operational gains.
  - Ensuring realistic sequencing and sustained political and financial support for reform continuity.

*Tax Administration Reform in Greece: Outcomes and Lessons (2010–25), April 2026 (IMF Note).*

### Box 1. Overview of Key Tax Policy Reforms in Greece, 2010–19

### Box 1. Overview of Key Tax Policy Reforms in Greece, 2010–19

### Overview
- Between 2010 and 2019, Greece undertook a comprehensive tax reform program aimed to restore fiscal sustainability, broaden the tax base, and modernize a tax system characterized by extensive exemptions, widespread tax evasion, and weak administrative capacity.
- Reforms affected major tax categories: value-added tax (VAT), personal income tax (PIT), corporate income tax (CIT), property tax, and excise duties.
- Reform phases: 2010–12 (immediate post-crisis stabilization), 2013–17 (structural and institutional transformation), 2018–25 (digital transformation and data-driven compliance).

### Personal Income Tax (PIT)
- Major reform: adoption of the new Income Tax Code (2013/effective 2014) simplifying PIT structure and improving neutrality across income categories.
- Policy changes:
  - Introduction of a new progressive tax scale with higher marginal rates.
  - Reduction or elimination of many exemptions and deductions.
  - Introduction of a temporary solidarity surcharge on personal income.
- Key numeric outcomes:
  - Top marginal PIT rate increased from 40 percent to 45 percent (for annual taxable income over 40,000 €).
- Labor tax wedge remained high during much of the period; reductions in social security contributions were introduced gradually toward the second half of the decade.

### Corporate Income Tax (CIT)
- Statutory CIT rate changes:
  - Increased from 20 percent to 26 percent in 2013.
  - Increased to 29 percent in 2015.
  - Reduced to 24 percent in 2019 as policy shifted toward growth-oriented reforms.
- Other measures:
  - New Income Tax Code established a more modern corporate tax framework with provisions aimed at reducing base erosion and improving alignment with international tax standards.
  - Withholding tax on dividends reduced from 10 percent to 5 percent in 2019.

### Indirect Taxes (VAT and Excises)
- VAT reforms:
  - Between 2010 and 2016, the standard VAT rate increased gradually from 19 percent to 24 percent.
  - Reduced VAT rates were also raised to narrow the rates gap and reduce incentives to reclassify supplies.
  - VAT base broadened by reducing exemptions and preferential rates.
- Compliance and enforcement:
  - Multiple preferential VAT regimes before 2010 contributed to a large compliance gap.
- Excises and sector levies:
  - Excises on fuel, tobacco, and alcohol were repeatedly increased.
  - Indirect taxes and sector-specific levies in energy, telecommunications, and consumption-based services were introduced or expanded.

### Property Taxes
- Major structural changes:
  - 2011: Emergency Special Property Charge introduced and collected through electricity bills to ensure compliance.
  - 2014: Emergency measure replaced by the Unified Real Estate Property Tax, establishing a broad-based system of recurrent property taxation covering buildings and land, based on administrative valuation system (“objective values”).
  - 2013 (effective 2014): Property transfer tax reduced from 10 percent to 3 percent, reflecting a shift away from transaction-based taxation toward recurrent property taxation.

### Tax Administration Reform Pillars and Sequencing
- Three broad phases organizing analysis and reform sequencing:
  - 2010–12: Immediate post-crisis stabilization — targeted enforcement measures and early digitalization initiatives.
  - 2013–17: Structural and institutional transformation — organizational consolidation, legal modernization, establishment of the IAPR.
  - 2018–25: Digital transformation and expansion of data-driven compliance tools — positioning Greece as a frontrunner in digital tax administration within EU.
- Reforms were interlinked, each phase building on earlier foundations to create a more agile, increasingly autonomous, and professional tax administration.

### Immediate Post-Crisis Reforms (2010–12)
- Objectives: stabilize revenues quickly, restore fiscal credibility, mobilize revenue from high-risk taxpayer segments, and improve collection of tax arrears.
- Anti-Evasion Plan (two-year plan initiated in 2010):
  - Risk-based compliance approach prioritizing large taxpayers, high-net-worth individuals (HNWI), and high-income self-employed persons.
  - Emphasis on intensified scrutiny and arrears collection.
  - Note: “Anti-Evasion” denoted compliance-oriented measures rather than criminal tax investigation.
- Digitalization of VAT compliance and electronic services:
  - VAT Automated Filing and Payment System implemented in May 2011.
  - TAXISnet platform upgrades between 2010 and 2012; mandatory electronic VAT filing established in 2011.
  - Key system features: automated matching to taxpayer register, reports identifying non-filers, computer-generated reminders and demand notices, centralized enforcement.
  - Compliance impact: on-time VAT filing rose from about 65–70 percent in 2010–11 to over 96 percent by 2014.
- Establishment of compliance units:
  - Large Taxpayer Unit (LTU) created to secure control over the top 1,000 taxpayers with full-service audit coverage, filing and payment control, intensified enforcement; faced resourcing and implementation challenges initially.
  - HNWI program launched to address evasion among high-income self-employed and wealthy taxpayers; initially lacked dedicated staff and specialized tools.
  - March 2012: large debtor unit launched targeting collecting revenues around €350 million by the end of 2014.
  - Early years: LTU and HNWI program delivered suboptimal results but laid groundwork for later risk-based audit programs.
- Strategic planning:
  - August 2011: Ministry of Finance published Strategic Plan for Tax Administration (2011–15).
  - Introduction of KPIs to monitor tax audit, debt collection, and organizational restructuring.
  - Consolidation of tax office network began.

### Structural and Institutional Reforms (2013–17)
- Shift from enforcement to deeper institutional transformation: governance, legal modernization, organizational restructuring, and autonomy foundations.
- Key institutional milestones and sequencing:
  - Early 2013: Strategic Planning Unit established reporting to Secretary General for Public Revenue.
  - July 2013: Program management office (PMO) established; became fully functional by October 2014 with launch of Strategic Planning Directorate.
  - 2013: Establishment of large taxpayer and HNWI audit centers (effectiveness constrained by limited financial data access and weak risk-profiling).
  - October 2014 onward: Functional reorganization of headquarters into a modern, function-based organization; full implementation extended into 2017/8.
  - By February 2018: headquarters encompassed centralized audit, collection, taxpayer services, and risk management.
  - Headquarters staff (tax and customs) reached 1,351—approximately 12 percent of the total staff.
- Consolidation of tax offices and centralization:
  - Between August 2012 and October 2013, number of tax offices reduced from 288 to 119 (15 months).
  - Debt collection and audit presence reduced to 61 offices by 2014.
  - New IT system for tax debt management (EISPRAXIS) released.
  - Staffing dynamics: auditor hiring during 2012–14 below projected benchmarks; overall staffing declined from 7,627 in February 2016 to 7,254 in September 2021.
- Workforce management and institutional autonomy:
  - January 2013: General Secretariat for Public Revenue (GSPR) established as organizational unit of the MoF to centralize tax audit responsibility and reduce fragmentation.
  - Transfer of staff from MoF and SDOE consolidated expertise within GSPR; transfers of IT resources occurred with delays.
  - 2017: Establishment of the Independent Authority for Public Revenue (IAPR) (see elsewhere for details).
  - 2017: Establishment of tax and customs academy and development of reform blueprint.
- Implementation constraints and evolution:
  - Early units (LTU, HNWI centers) and reforms initially limited by staffing, analytical capacity, access to financial data, and legal frameworks; nonetheless, they established the foundations for subsequent scaling-up and improved compliance strategies.

*Source: insea2026003 - Box 1. Overview of Key Tax Policy Reforms in Greece, 2010–19*

### Introduction of Tax Procedures Code

### Introduction of Tax Procedures Code

### Introduction of the Tax Procedure Code (TPC)
- A landmark legislative reform was enacted in January 2014 with the introduction of the Tax Procedure Code (TPC).
- The TPC consolidated procedural provisions previously scattered across substantive legislation and provided a comprehensive legal framework for tax administration, dispute resolution, and taxpayer rights and obligations.
- Implementation was phased and required secondary legislation and enabling measures to operationalize many provisions.
- By March 2016, several supporting measures—such as automated estimated assessments for non-filers, tax rulings, and electronic notifications—remained pending.
- The TPC was designed to promote transparency, consistency, and legal certainty in tax administration.
- Complementary reforms accompanying the TPC included:
  - Establishment of a Dispute Resolution Unit in September 2013.
  - Expansion of installment programs.
  - Elimination of in-person payments at tax offices in favor of electronic and bank-based transactions.
- Collective effect: modernization of the tax system, enhanced taxpayer experience, and support for voluntary compliance.

### Establishment of the Independent Authority for Public Revenue (IAPR)
- IAPR began operations on January 1, 2017.
- Reform objectives:
  - Alter incentives and decision-making authority.
  - Enable advances in HR reform, risk management, and digitalization.
  - Provide operational and financial autonomy to shield decisions from political interference and strengthen governance.
- Institutional design and timeline:
  - IAPR established as operationally and financially autonomous, distinct from the previous GSPR.
  - Contrary to earlier transitional arrangements, personnel from the SDOE were not initially integrated; SDOE was incorporated as a new general directorate within IAPR at the end of 2025.
  - The institution is headed by a Governor, supported by a management board originally created to facilitate transition and reinforce independence.
- Budget and staffing:
  - Article 19(3) of Law 4389/2016 established a binding budgetary safety net to ensure uninterrupted financing and prevent funding from falling below what is necessary to fulfill IAPR’s mandate.
  - Operational budgets at IAPR increased from €411 million in 2017 to €507 million in 2025—an average annual growth of approximately 3 percent—although net staffing levels remained stable or declined throughout much of the reform period.

### Merit-Based Leadership Appointments
- Law 4389/2016 established a formalized framework for appointing the Management Board and the Governor of IAPR grounded in openness, merit, and procedural transparency.
- Selection and appointment procedures:
  - Management board members selected through an open competition under modalities set out in a ministerial decision published in the Government Gazette and online.
  - Candidates evaluated against predetermined, objective criteria by an independent Selection Committee comprising senior representatives from:
    - the Supreme Council for Civil Personnel Selection,
    - the Parliamentary Budget Office,
    - the MoF,
    - the Fiscal Council,
    - an academic member,
    - and initially two European Commission (EC) designees.
  - The Selection Committee submits a competitively generated shortlist—twice the number of vacancies—from which the Minister may appoint candidates, subject to approval by the Parliament’s Committee on Institutions and Transparency.
  - Appointment of the Governor follows the same principles:
    - open competition,
    - identification of the eight strongest candidates by the Selection Committee,
    - ranking of the top four by the management board,
    - final ministerial appointment from this ranked list, with the decision and its rationale published.
- Effect: substantive curtailment of discretionary power and insulation of senior appointments from ad hoc political intervention; strengthened independence, credibility, and professionalism of tax administration leadership.

### Tax Administration Reform Blueprint (2018–25)
- First Reform Blueprint produced in December 2017 covering 2018–2020; detailed a new business model across five components: comprehensive service, upgraded enforcement, people, technology, and infrastructure.
- A robust annual business-planning process was adopted to define operational activities for each year.
- Revised Reform Blueprint released in December 2020 covering 2021–2025 with an ambitious agenda across IT, HR, organization design, business processes, and service delivery.
- Centralization was a major theme of transformation.
- Program scale and financing:
  - By 2023, there were 19 projects within IAPR having EC’s Recovery and Resilience Fund (RRF) financing of €290 million that is contingent upon satisfaction of major milestones through to the fourth quarter of 2025.
  - In addition, IAPR is implementing an additional 31 reform projects tied to other financing sources between now and 2027.
- Implementation challenge: the large and complex reform program stretched organizational capacities while requiring maintenance of operational performance and delivery of public support programs as required by the government.

### Digital Transformation and Compliance Tools, 2018–25
- Reform emphasis shifted from platform development to real-time, analytics-based tax administration leveraging digitalization and data-driven compliance tools.
- Alignment: digitalization efforts aligned with the government-wide strategy led by the Ministry of Digital Governance, especially after 2019.
- Key milestones (by year):
  - 2019
    - BI and DW modernization
  - 2020
    - Digital pandemic responses, for example, my Business Support
    - Launch of myDATA
  - 2021
    - myAADE digital portal platform
  - 2022
    - Launch of the Appodixi app
    - Prefilling of VAT
  - 2023
    - Prefilling of CIT
    - Developing auditLIVEAADE System
    - Mandatory e-invoicing for B2G
  - 2024–25
    - Mandatory POS connection to cash register
    - Mandatory reconciliation of sales and expenses

### Expansion of E-services: From TAXISnet to myAADE
- Near-universal online service delivery accelerated significantly by 2020, with COVID-19 acting as a catalyst.
- Key services introduced or enhanced:
  - “my Business Support” for financial aid
  - “myProperty” for real estate declarations
  - “myAppointment” for scheduling office visits
  - “myAADElive” for video call
  - Obtaining a Taxpayer Identification Number online
  - “myRequest” multiservice platform for a single digital pathway for multiple services
  - “Fees by the Month” application in myCAR for lifting immobilization status by paying proportional road tax monthly
  - 2021 launch of the platform for VAT declarations under the One-stop-shop (OSS) e-commerce service, including electronic implementation of OSS/import OSS programs and adaptation to EU Directive 2017/2455
- myAADE Digital Portal:
  - Developed in September 2021, phasing out myTAXISnet.
  - Provides comprehensive access to all AADE digital services including tax declarations, payment arrangements, property and vehicle taxation, and myDATA e-books.
  - Enables account and contact management; viewing official communications; tracking debts, payments, and refunds; direct payments or installment plans; printing monthly account statements; submitting digital requests and administrative appeals; scheduling appointments with AADE officers; and correcting pre-filled tax declaration data before automatic filing.

### The myDATA Platform: Continuous Transaction-Level Reporting
- myDATA launched in 2020 and marked a structural break from ex post reporting toward continuous, transaction-level visibility for VAT and income tax compliance.
- Adoption timeline and scope:
  - Initially voluntary; became mandatory in November 2021 with the scope of transmission gradually expanded.
  - All businesses are now required to transmit accounting data electronically to myDATA platform with multiple channels available for invoice submission, including Enterprise Resource Planning integration, authorized e-invoicing service providers, web-based forms, and electronic tax mechanisms for retail, such as online cash registers (Maragou 2024).
  - Real-time transmission of invoices and accounting entries became mandatory from 2024.
- Functional and compliance features:
  - myDATA supports B2B, B2C, and B2G transactions.
  - Includes quick response (QR) codes for invoice verification and strict reconciliation rules for VAT returns.
  - Enforces that VAT returns must match the data uploaded to myDATA, with discrepancies flagged for review.
  - Penalties are applied for failure to comply with myDATA obligations.
  - myDATA aimed to improve VAT and corporate income tax (CIT) compliance, requiring transmission of sales invoice synopses and other transaction types to enable calculation of businesses’ income tax obligations.

*Source: insea2026003 - Introduction of Tax Procedures Code*

### Box 2. MyDATA Transaction Types

### Box 2. MyDATA Transaction Types

### MyDATA transaction types (as listed)
- Sales invoice
- Receipt for retail sales
- Invoice for services rendered
- Credit notes for retail sales
- Acquisition title
- Contract (revenue or expense)
- Credit notes for invoices
- Special record (receipt)
- Records for self-supply—private use
- Personnel expenses
- Transport document
- Depreciation
- Receipt for services rendered
- Other adjusting entries for revenues/expenses

### E-invoicing rollout and reporting mandates
- Mandatory e-invoicing was rolled out in phases, starting with large businesses and public sector contracts and gradually expanding to cover all businesses.
- The obligation for B2G e-invoicing began in September 2023 and was fully implemented by January 2025.
- In July 2025, the EU approved mandatory B2B e-invoicing for all domestic transactions.
- All invoices (including B2B, B2C, and B2G) must be reported online to myDATA, with QR codes for verification and direct access to invoice details.
- From January 2024, all retail businesses are required to use POS terminals connected to cash registers for issuing receipts, with mandatory POS connections extended in May 2024.
- POS devices are integrated with myDATA, enabling real-time transmission of retail (B2C) transaction data.
- Initial pilots (for example, gas stations) revealed that only 50 percent of businesses were ready to provide live data by the mandated start date.
- The volume of transactions is substantial—estimated at 500 million per year—necessitating robust IT infrastructure and data management processes.
- Non-compliance with POS and invoice-reporting obligations results in penalties, with additional ministerial decisions specifying implementation details.

### Business Intelligence (BI) and Data Warehouse (DW) modernization
- The initial DW, installed in 2014, was underused because of incomplete data and unclear business requirements.
- A major BI modernization program was launched in May 2019, backed by the RRF.
- External consultants developed a comprehensive BI road map covering architecture, technology evaluation, and governance.
- Pilot projects—such as fuel tax monitoring (inflow–outflow system)—helped shape the full BI system, which follows the Corporate Information Factory model and supports data marts, analytics, and reporting tools.
- The DW is currently being expanded to integrate real-time transaction data from myDATA, enabling advanced analytics and enhanced compliance risk management (CRM).
- In January 2024, automated VAT refund risk assessment software was deployed, reducing manual audits and accelerating refund processing.
- BI dashboards track KPIs across tax collection, filing compliance, and service delivery; BI tools can identify non-compliance patterns, automate risk scoring, and enable targeted audits.

### Pre-filling of VAT and CIT returns
- Pre-filling of VAT returns began in December 2022, using the transaction-level data from myDATA.
- As of January 2025, deviations between sales and expenses records are not permitted.
- Pre-filling of annual income tax forms started in January 2023, leveraging the data from myDATA and other sources.
- Technical workflow: myDATA aggregates transaction data, reconciles it with accounting books, and generates draft VAT and CIT returns for taxpayer review. The system flags mismatches and missing data, prompting taxpayers to resolve issues before submission.

### Further digitalization and real-time audit tools
- The Appodixi (“Receipt”) app was launched in 2022 to enable taxpayers to verify transaction receipts by scanning QR codes and report discrepancies or untransmitted receipts anonymously or by name.
- AuditLIVEAADE was developed in August 2023 to equip auditors with real-time access to taxpayers’ financial profiles on tablets, enabling live monitoring of receipt transmissions, data cross-checking, and issuance of penalty reports.
- The Bankapp (Bank Account Nexus Crosscheck Application System) was launched in January 2024 to automate the assessment of wealth increase.
- Digitalization extends from business registration (allowing sole proprietors to initiate activity online without prior registrations with commercial and social security registries) to streamlined registry procedures covering certificates, tax clearances, company changes, and vehicle-related services.

### Professionalizing the workforce and HR reforms
- HR reforms under the IAPR Law established a bespoke framework for staffing, mobility, promotions, and remuneration within the IAPR, including deviations from the standard public sector HR regime.
- A bonus incentive program was introduced in December 2017.
- The Tax Academy was launched in February 2018 to provide comprehensive training programs.
- A staff appraisal program was implemented in July 2019.
- A pay and grading reform was enacted in 2021 to better align compensation with job responsibilities.
- By 2023, audit and collection functions were centralized into six national audit centers and two debt collection centers.
- The rapid consolidation of the tax office network reduced tax offices from 288 to 119 over just 15 months.
- Staffing levels remained broadly flat or declined after 2010; downsizing between 2011 and 2016 constrained capacity despite productivity improvements, and persistent recruitment shortfalls—particularly in specialized areas—limited alignment of staffing with operational needs.

### Reform impact: revenue and compliance outcomes (key statistics)
- Tax-to-GDP ratio: 20.5 percent in 2009, climbing steadily to over 28 percent in 2025.
- VAT compliance gap: decreased from 30 percent in 2011 to 9 percent in 2024. The overall reduction in the compliance gap from 2011 to 2024 is 21 percent.
- VAT e-filing: reached 100 percent since 2022.
- CIT e-filing: attained 99.9 percent from 2021 onward.
- E-payment adoption: rose from 86.6 percent in 2018 to 99.2 percent in 2023.
  - Notable increase from 90.4 percent in 2021 to 98.8 percent in 2022.
- Tax arrears: closing stock arrears as a percentage of total revenue fell sharply after 2018, dropping 69.3 percent between 2020 and 2023.
  - CIT arrear rate decreased from 893.1 percent in 2020 to 233.1 percent in 2023.
- Despite arrears declines, a large legacy of long-aged and low-collectability debt remains; a significant share of outstanding arrears is unlikely to be recoverable in full.

### Institutional diagnostics and performance indicators
- Operational Strength Index (OSI): composite metric based on ISORA data, aggregating responses to 193 survey questions across nine sub-indices (including CRM, UTD, degree of digitalization, service orientation, public accountability, autonomy (AUT), large taxpayer office and HNWI, tax enforcement, and HRM). For the IAPR, OSI showed notable improvements since 2015, especially from 2017 onward.
- OSI sub-indices showing significant progress include UTD, AUT, and HRM; six areas—CRM, UTD, AUT, large taxpayer office and HNWI, tax enforcement, and HRM—outperform those of advanced economies and EUR in 2022.
- TADAT assessments: comparison of two assessments shows significant progress over a five-year period. Five out of thirty-two indicators meet international good practices.
  - Improvements noted between 2018 and 2023 include: scope of initiatives to reduce taxpayer compliance costs (POA 3-10), timeliness of payments (POA 5-17), use of large-scale data-matching systems (POA 6-20), adequacy of the tax revenue accounting system (POA 8-27), and internal assurance mechanisms (POA 9-29).
- Taken together, OSI and TADAT performance improvements—alongside a VAT compliance gap still slightly above the EU average—reflect that institutional maturity has advanced faster than behavioral convergence; further integration of real-time reporting, analytics-driven risk management, and differentiated treatment strategies is needed for convergence toward EU averages.

### Implementation challenges
- Resistance to organizational change and staffing constraints slowed reform absorption; consolidation from 288 to 119 tax offices over 15 months generated uncertainty.
- Lag in secondary legislation impeded full implementation of major legislative reforms enacted in January 2014; as of March 2016 many enabling measures remained pending.
- Dispute resolution bottlenecks persisted, with high rates of taxpayer disputes—especially among HNWI—slowing processes despite establishment of a Dispute Resolution Unit.
- Ongoing reform actions to address arrears include improved debt segmentation, increased automation of collection actions, and clearer write-off and insolvency procedures.

*Source: insea2026003 - Box 2. MyDATA Transaction Types (IMF Note).*

### 1. Closing Stock Arrears at Year End as Percent of Total

### 1. Closing Stock Arrears at Year End as Percent of Total Revenue Collected

### Arrears level (annual series)
- 2018: 213.1
- 2019: 191.5
- 2020: 228.3
- 2021: 203.0
- 2022: 190.6
- 2023: 159.0

### Arrears by tax type (chart labels preserved)
- Tax categories shown: CIT, PIT, VAT

### Key findings on reform implementation and performance
- Audit selection procedures were revised only belatedly; the share of targeted cases encompassing older tax years remains too high, reducing impact on current compliance and debt collection.
- Since 2017, IAPR’s operational budgets have increased at an average annual rate of 3 percent.
- Net staffing levels for tax and customs administration have remained flat or declined, limiting the ability to invest in new technologies, training, and service delivery.
- Only 23 percent of VAT refunds were processed within 30 days as of the 2023 TADAT assessment, despite the deployment of new risk assessment software.
- The DW, installed in 2014 as the first iteration of new BI tools, was initially underused due to incomplete data coverage and unclear business ownership and requirements.
- By 2021, major BI infrastructure projects remained unfinished and the IAPR lacked a robust BI center of expertise.
- The gradual implementation of myDATA was hampered by technical and capacity constraints:
  - Transaction-level reporting commenced later than planned.
  - Pre-filling of VAT declarations did not begin until December 2022.
  - Flexible reporting channels for myDATA have not achieved universal coverage; take-up rates remain unclear.
  - Mandatory adoption of e-invoicing for B2G and B2B transactions has been delayed, pending secondary legislation.
- The Dispute Resolution Unit renders explicit decisions in more than 95 percent of cases, rather than defaulting to implicit rejection through administrative silence.
- Additional cross-cutting implementation constraints:
  - Project and change management capability: initial project teams lacked effective scoping and planning skills.
  - Understanding of functional model and risk management: poor initial understanding and resistance hampered CRM development.
  - Governance and decision making: unnecessarily centralized decision making overwhelmed leadership and delayed strategic activities.
  - Resource prioritization: persistent constraints required careful prioritization and redeployment of capable staff for quick wins.

### Role and chronology of IMF capacity development (CD) support (Table 1 entries)
- 2010 — Anti-evasion plan design: IMF support in designing the Anti-Evasion Plan, including strategic focus on large taxpayers and debt collection
- 2011–15 — Strategic plan development: Assistance in drafting the Strategic Plan for Tax Administration and defining performance benchmarks
- 2013–14 — PMO establishment and governance support: Support in setting up the PMO and Strategic Planning Directorate
- 2014–17 — Audit and collection strategies, HR reforms: Development of audit and collection strategies, support for HR reforms including pay and grading structures
- 2018–20 — Reform blueprint drafting, IT modernization: Technical assistance in drafting the Reform Blueprint and modernizing IT systems
- 2021–23 — BI and risk management frameworks, training programs: Support for BI tools, risk management frameworks, and capacity building through training programs
- 2024–25 — Monitoring and implementation of digital reforms: Ongoing support for monitoring reform milestones and implementing digital platforms such as myDATA

### Lessons learned and strategic implications
- Political support and management commitment:
  - Sustained leadership and clear political backing were critical; legislative action and ministerial support were necessary to establish IAPR autonomy.
  - Selection of the Governor through a merit-based and competitive process supported independence and credibility.
- Sequencing of reforms:
  - Clarifying policy and operational objectives and establishing legal and institutional foundations before advanced digital solutions proved important (example: TPC in 2014).
- Value of autonomy and governance reforms:
  - Establishment of IAPR in 2017 enhanced credibility, stakeholder confidence, and enabled risk-based compliance strategies and performance-based management.
- Need for sustained investment in BI and IT infrastructure:
  - BI modernization program launched in 2019 introduced a road map and pilot projects.
  - Deployment of automated VAT refund risk assessment software in 2024 exemplifies analytics potential.
  - Without clear business ownership, governance arrangements, and sustained skills investment, data infrastructure cannot be used effectively.
- Expanding CD to support change management and institutional capacity:
  - CD should encompass organizational development and HR strategies in addition to technical advice; tailored training and leadership development mitigate resistance.
- Innovative funding models:
  - Authorities leveraged external funding sources, including the RRF, focused on digital transformation and improving access to digital services.
  - Innovative funding models such as performance-based financing and donor coordination can help sustain reform momentum.
- Service orientation and taxpayer trust:
  - As processes become automated, perceptions of fairness, transparency, and accessibility will shape voluntary compliance.
  - Integrated digital services, simplified procedures, and pre-filled declarations can reduce compliance costs and lower error rates.

### Strategic priorities going forward
- Consolidation, effective use, and long-term institutional sustainability of reforms rather than new design or launches.
- Systematic strengthening of data analytics, including selective and responsible use of artificial intelligence (AI), and full integration into CRM by design.
- Embedding analytical and AI-enabled tools directly into core CRM workflows covering risk segmentation, audit selection, case treatment, dispute resolution, and debt collection.
- Continued investment in skills development, leadership, and performance management through institutions such as the Tax and Customs Academy of the IAPR.
- Maintaining a stronger taxpayer-centric approach with simplified procedures and pre-filled declarations to reinforce voluntary compliance.
- Clear strategic direction through the Blueprint, disciplined sequencing, and realistic implementation planning to align reform ambitions with institutional capacity and fiscal constraints and to progress toward Tax Administration 3.0 (OECD 2020).

*Tax Administration Reform in Greece: Outcomes and Lessons (2010-2025) NOTE/2026/003*

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_Source: https://www.imf.org/-/media/files/publications/imf-notes/2026/english/insea2026003.pdf_