Bank Deposits Audit in Greece by Tax Authorities
Bank Deposits Audit in Greece by Tax Authorities: Legal Updates on the Statute of Limitations (2025)
In recent years, the Greek tax authorities have intensified audits concerning undisclosed bank deposits. These audits often target Greek taxpayers with significant sums in domestic or foreign bank accounts, raising issues of potential tax evasion. One of the most critical legal aspects of these audits is the statute of limitations, which determines how far back the authorities can investigate and impose taxes or penalties.
This article provides an updated legal overview (2025) on how bank deposits audits in Greece are handled and the evolving case law regarding limitation periods.
1. Why Bank Deposits Trigger Tax Audits in Greece
The Greek Independent Authority for Public Revenue (AADE) uses various data sources—such as information from Greek banks, cross-border data exchanges (CRS), and whistleblower tips—to flag discrepancies between declared income and bank account balances. If a taxpayer’s bank deposits exceed declared income, the tax authorities may assume the existence of undeclared income, unless the taxpayer can prove the legal origin of the funds.
2. Legal Basis for Audits of Bank Deposits
The core legal principle applied is the “reversal of the burden of proof”: if unexplained bank deposits are identified, the taxpayer must justify their origin (e.g., past savings, inheritances, gifts, or loans). If the justification is insufficient, these amounts may be taxed as undeclared income under Greek tax law.
3. Statute of Limitations for Tax Audits in Greece
Understanding the statute of limitations (παραγραφή) is crucial for defending against audits. Greek tax law has undergone significant changes and judicial scrutiny on this issue, especially regarding bank deposit audits.
Key Limitation Periods (As of 2025):
• 5 years: The general limitation period for tax audits.
• 10 years: If new evidence emerges that was previously unknown to the tax authority.
• 20 years: In cases of intentional tax evasion or fraudulent activity.
However, recent decisions by the Greek Council of State (ΣτΕ) have restricted the unlimited extension of audits based on vague or unverified “new evidence.”
4. Recent Court Rulings: Protection Against Retroactive Audits
Several landmark decisions by the Council of State (StE 1738/2017, 320/2022, 622/2023) have:
• Invalidated audits based on bank deposit data that lacked proper documentation.
• Clarified that data leaks or old bank account movements (such as from the 2000s) do not automatically justify a 10-year extension.
• Reaffirmed the principle of legal certainty and the taxpayer’s right to finality.
These decisions are now shaping the way the AADE must approach audits related to older banking transactions.
5. Legal Strategy for Taxpayers Under Audit
If you are subject to an audit concerning bank deposits in Greece, it is essential to:
• Review the justification of the audit period.
• Request the specific evidence on which the tax authority bases its extension of the statute of limitations.
• Prepare documentary evidence to explain the origin of the deposits.
• Consider filing administrative objections or appeals before Greek courts, especially if the limitation period has expired.
6. How Economou & Economou law office Can Help
At Economou & Economou, we have extensive experience in defending clients in bank deposit audits and tax disputes before Greek administrative courts. Our legal team has successfully annulled tax assessments based on unlawful extensions of limitation periods and unsubstantiated evidence.
We provide:
• Legal representation in AADE tax audits and court appeals
• Strategic defense against audits based on old or foreign bank data
• Expert advice on the statute of limitations and protection of your rights
Cases Successfully Handled by Economou & Economou Law Office
1. Case A – High-Income Professional With €450,000 in Deposits (2017–2018):
A self-employed consultant was audited in 2023 for unexplained deposits from 2017 and 2018. The tax authority attempted to impose retroactive income tax and penalties. Our office filed an appeal based on the Council of State’s recent rulings. The court accepted our argument that the audit was time-barred. Result: Full cancellation of tax assessments and penalties.
2. Case B – Small Business Owner Flagged for Transfers to Germany:
A Greek business owner was targeted for €120,000 in transfers to a personal German account made in 2014–2015. The authorities attempted to recharacterize the transfers as undeclared income. We proved that the transfers were outside the audit window and did not constitute new evidence. Result: Tax audit closed with no action taken.
3. Case C – Retiree With Dual Nationality and Foreign Account in Canada:
A dual Greek-Canadian citizen was audited in 2022 for deposits in a Canadian bank account from 2011–2012. Our team successfully argued that these foreign accounts were outside the 10-year statute of limitations. The Tax Dispute Resolution Directorate agreed. Result: Case dismissed, with no taxes due.
What This Means for Taxpayers
As of January 1, 2025, the tax authority will no longer be able to audit 2018 banking activity, regardless of whether deposits or transfers align with declared income. The focus is now shifting to 2019 and subsequent years, with 2019 becoming time-barred on December 31, 2025.
Taxpayers can now feel more secure about past banking activity but should remain vigilant regarding financial movements from 2019 onward.
Need Expert Tax Defense?
Economou & Economou Law Office, named among the Best Law Office in Greece by Lawzana, is a leader in high-stakes tax litigation and audit defense. Our team has successfully defended clients before Greek tax authorities and administrative courts.
Contact Economou & Economou Law Office
📧 Email: econlaw@live.com
📞 Phone: (+30) 210 3603824
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