Until now, any taxpayer wanting to sell real estate while having overdue debts under suspended collection would see 50% of the transaction price automatically withheld by the tax office. Regardless of whether the debt had been “frozen” due to a court appeal or a decision by the Dispute Resolution Directorate (DED), the Independent Authority for Public Revenue (AADE) required half of the sale amount to be withheld as a “guarantee” for debt repayment.

Under a new decision by AADE Governor Giorgos Pitsilis (A.1072/2025), this changes significantly. The withholding can now be limited to just 5% of the sale price, provided certain conditions are met.

Specifically, the favorable treatment applies to taxpayers with a principal debt exceeding €50,000 that is under suspended collection—either due to a court ruling or a decision by the Dispute Resolution Directorate (DED). In order to reduce the withholding from 50% to 5%, the debtor must provide sufficient security for the State.

This can be achieved in one of two ways:

1. Providing a guarantee (bank or other form), or
2. Registering a first mortgage on another property owned by the taxpayer.

In the case of a mortgage, the AADE will accept the security based on 80% of the property’s objective (assessed) value. If the mortgage value does not fully cover the debt to justify the 5% withholding, then the withholding is adjusted proportionally—e.g., to 10%, 20%, 35%, etc.—depending on the coverage offered.

Example:
A property owner has a suspended debt of €80,000 and sells a property for €200,000. If they offer another property (e.g., a plot of land) with an assessed value of €100,000 and register a first mortgage on it, the AADE accepts 80% of that value—i.e., €80,000—as sufficient security. Thus, the withholding drops from €100,000 (50%) to €10,000 (5%), improving the taxpayer’s liquidity and facilitating the transfer.

What applies to other cases:

• For those with structured and current payment plans on overdue debts, a tax clearance certificate is issued digitally with a 70% withholding on the sale price, up to the total amount of the debt—provided the sale price is equal to or higher than the property’s assessed value. If it’s lower, a 70% withholding on the sale price is applied first, and if insufficient, it’s calculated on 70% of the assessed value—on the condition that the total withheld amount does not exceed the sale price.
• For those with unstructured overdue debts exceeding €30, not under any repayment plan or collection suspension, no tax clearance certificate is issued. In these cases, and provided the necessary tax filings have been submitted and there are no other holds, a Certificate of Debt is issued digitally via myAADE, enabling the completion of the property transfer.