The Greek Independent Authority for Public Revenue (AADE) is activating the ability to sell properties under seizure, even when the sale price cannot fully cover the owner’s outstanding debt to the tax authority. Under the new framework, a seized property can be released even with partial debt repayment — a development that significantly benefits property owners looking to sell or otherwise make use of their assets.
AADE’s decision on the sale of seized properties
Until now, lifting a seizure and completing a property transfer typically required full repayment of the outstanding debt.
That is set to change under a new decision (A.1158/2026) issued by AADE Governor Giorgos Pitsilis, which puts into practice Article 47A of the Tax Procedure Code (Article 18 of Law 5293/2026). The decision introduces greater flexibility in property transfers, making the process easier for taxpayers and helping to unblock transactions in the real estate market.
To release a seized property, the debtor must submit a seizure-lifting request digitally through the myAADE portal (myaade.gr) via the “My Requests” application, following this path: myAADE Digital Services > My Requests > Legal, Measures and Debts > Lifting of seizure imposed on a property ahead of its transfer for consideration.
The conditions
For the seizure to be lifted and the transfer for consideration (e.g., a sale) to proceed, three cumulative conditions must be met:
The debtor must be entitled, at the time of the release, to a tax clearance certificate or a debt confirmation statement (Article 12 of the Tax Procedure Code).
The sale price must not be lower than the property’s market value as determined at the time the seizure was imposed, or its objective value — whichever is higher.
From the transfer price, the notary must withhold and remit to AADE an amount equal to at least one quarter (25%) of the current outstanding seizure balance. However, the final percentage may be higher, based on the debtor’s tax compliance record and the recoverability of the remaining debt.
If the amount resulting from the seizure withholding exceeds the amount specified in the tax clearance certificate or debt confirmation statement, the higher amount will apply.
Once all conditions are met, a formal decision is issued and sent to the debtor along with a document detailing the calculation of the weighting factors for tax compliance and recoverability of the remaining debt.
Illustrative example
For example:
An individual wishes to sell a property on which a seizure of €80,000 has been imposed.
If, based on tax compliance criteria, the debtor achieves the highest possible score (100 points), the withholding rate is set at the minimum threshold of 25%.
In this case, to lift the seizure:
€20,000 (25% × €80,000) will be withheld from the sale proceeds — unless the provisions on tax clearance or debt confirmation require a higher amount, in which case the higher figure must be withheld in order for the seizure to be lifted (Article 12 of the Tax Procedure Code).
Once this amount has been paid, the seizure can be lifted and the transfer completed.
Under the previous regime, the same taxpayer would have been required to repay the full €80,000 in order for the property sale to proceed.
