In real-estate transactions, the era of “double prices” is coming to a definitive end. AADE no longer relies on what the contract states; instead, it follows the banking trail and, wherever it detects a higher payment, it recalculates the tax and imposes fines.

The recent Council of State decision 848/2025—issued for a 2008 transfer in which the objective value had been declared while a much higher amount had been paid—confirms that the contract offers no protection when bank accounts show a different reality. The Tax Administration may now bypass the stated price and tax solely on the actual money that changed hands.

The case reveals the new method of control. Although the contract listed a price of €383,815.99, the banking footprint showed a total payment of €650,000. The difference led AADE to reassess the transfer tax and impose a fine for inaccurate price declaration. The local tax office imposed a fine for inaccurately reporting the price, the Dispute Resolution Directorate tacitly rejected the company’s administrative appeal, and the Administrative Court of Appeal ultimately applied the more lenient subsequent regime, limiting the fine to 25% of the concealed value.

The decision clearly establishes that, in real-estate sales, tax truth prevails over the formal wording of the contract: if the banking trail indicates a higher price, that amount is accepted as the real one.

Decision 848/2025 essentially draws a new line in the market: AADE can now scrutinize, compare, and challenge any contract that does not “match” the bank transactions. “One amount on paper, another in the bank” can no longer withstand modern audit tools. Cross-checks of data, electronic filings, and complete visibility of account activity make it nearly impossible to hide a higher payment. In this environment, transactions built for decades on the Greek practice of “objective value on the contract – real value in practice” are now under constant risk of detection.

The market’s “trick” was straightforward: writing the objective value as the official price and agreeing on the remainder “under the table”—whether through cash, parallel transfers, deposits into relatives’ accounts, old cheques, or set-offs. In some cases, the payment was broken up into many small accounts to obscure the trail.

This system worked as long as digital monitoring was limited. Today, with mandatory use of banking methods and fines starting at 10% and reaching up to €500,000 for amounts moved outside the banking system, concealment has become dangerous, costly, and nearly impossible to slip through.

At the same time, AADE has opened a targeted front on property transfers. Thousands of contracts are being examined, with discrepancies in price being one of the most common reasons for re-reviewing files. Case law is now stable and aligned: the contract is merely one element of the case—when the bank records say otherwise, the bank records tell the truth. The real price is considered to be the one reflected in the bank account, not the one appearing in the notarial deed.