A recent ruling by the Administrative Court of Thessaloniki is challenging Greece's tax and legal precedent, allowing authorities to extend tax audits from five to 10 years based on new, named whistleblower complaints.
The decision has alarmed legal experts, who warn it could allow authorities to reopen thousands of old cases.
The ruling directly challenges a long-standing precedent set by the Council of State, Greece's highest administrative court.
Nearly eight years ago, the Council of State affirmed a strict five-year statute of limitations for tax cases, ruling it could only be extended if "new and supplementary evidence" was discovered.
The Thessaloniki court, for the first time, has ruled that a signed citizen complaint qualifies as such evidence.
The case involved a mussel farmer who contested a tax bill for unpaid VAT from 2004 to 2011, totaling over €70,000.
The farmer argued the five-year deadline had passed.
The court, however, upheld the audits for 2006-2011, citing a 2015 named whistleblower complaint as new, material information that justified the 10-year extension.
The decision comes as citizen reports to the Independent Authority for Public Revenue (AADE) are surging.
As of last week, AADE's online platform had received over 68,000 complaints.
The 8,552 named complaints, which now take on new legal significance, are typically prioritized for review. Legal analysts expect the case to be appealed.
By Yiorgos Pappous