Greece allows sale of tax‑seized properties with partial debt repayment
Under Article 47A of Law 5293/2026 AADE may lift seizures if part of the unpaid tax is paid from sale proceeds; notaries must withhold at least 25%.
Greece has approved a regulatory framework that allows certain tax‑seized properties to be sold without requiring owners to repay their full outstanding tax liabilities before completing the transaction. The change, published on 04 August, 2026, gives the tax authority greater discretion to accept partial repayment from sale proceeds.
How the new rule works
Under Article 47A of Law 5293/2026, the Independent Authority for Public Revenue (AADE) may lift a seizure on a property when the owner pays part of the unpaid tax directly from the proceeds of a sale. The decision is not automatic: AADE will assess the property's value, the agreed transaction price, the taxpayer's past compliance record and the likelihood of collecting the remaining debt before authorising release.
To apply for release, owners must submit an electronic request through the myAADE platform: myAADE digital services → My requests → Judicial cases, enforcement measures and debts → Release of seized immovable property prior to transfer for consideration. If the seizure is lifted, the owner must be eligible for a tax clearance or a certificate of unpaid debt under Article 12 of the Tax Procedure Law; those documents establish the outstanding obligations and the sum the notary must withhold from the transaction proceeds.
The agreed sale price cannot be set below the commercial value of the property as assessed at the time of the seizure. Where the official tax valuation — known in Greece as the "objective value" — is higher, the seller must set the transaction price at or above that figure. That rule aims to prevent transfers below recognised value that would reduce amounts available to satisfy unpaid taxes.
Notaries overseeing the transaction are required to retain and forward to AADE an amount equal to at least 25 percent of the remaining debt covered by the seizure. AADE may demand a higher retention after reviewing the taxpayer's compliance history and the prospects for collecting the outstanding balance. When tax clearance rules or the certificate of unpaid debt require a larger payment, the notary must transfer the higher amount.
Authorities and market participants expect the reform to unlock sales that had been stalled because owners could not raise the full tax sum up front. By allowing qualified owners to finance a partial repayment from sale proceeds, the framework seeks to increase transaction fluidity while preserving the state's ability to recover unpaid taxes.
Photo: press material from the event
