Greece is once again immersed in a corruption scandal – this time against the backdrop of OPEKEPE. And we are once again becoming spectators to the same ill-fated play, one of those that led the country to bankruptcy and international disrepute. Back to factory settings.
The issue is not only the 450 million euros lost by those who were entitled to them and hoped to build a better tomorrow for themselves and their families. The real cost is many times greater: we are talking about billions that the Greek economy and its growth path have been deprived of.
However, for every problem there is a solution – as long as it’s smart and effectively designed.
The game-changing circular
In April 2024, the AADE issued Circular E2024/2024, according to which any property leased through a short-term lease by a legal entity is considered a business establishment – i.e. a branch – and is subject to a business tax of 600 euros per property.
According to the circular:
“Properties leased or subleased under Article 111 of Law No. 4446/2016 by legal persons or legal entities, without the provision of services other than the provision of bedding, are considered as business premises and the provisions of Article 31 of Law No. 3986/2011 on the imposition of business tax.”
In practice, with a deletion of the word “not” (NOT counted as business premises) from all previous wording in the laws, the AADE attempted to impose an additional tax burden on property management companies – in an arbitrary manner, without legislative provision, without sufficient justification, unconstitutionally and of course without prior consultation.
The CoE’s reply
The Association of Short Term Lease Companies (Stama Greece) appealed to the Council of State, which by decision 602/2025 ruled by a majority (5-2) in favour of the application for annulment (not final but with binding reasons) that:
“The mere granting of a property for short-term lease does not imply a commercial or productive activity within the property. Therefore, it cannot be considered a branch office.”
The final judgment was referred to the Plenary Session of the CoE for December 2025.
And yet they insist
Instead of refolding and taking into account the judgment of the Supreme Court, the Government returns with a new bill: article 248 of Part B (“National Customs Code and Other Provisions”) and attempts to legislate retroactively the same unconstitutional regulation – with retroactive effect from 1/1/2024.
This is a clear violation of basic principles of the rule of law and constitutional order. And, moreover, without assessing the consequences:
- Management companies operate through contracting out by owners – so the financial burden is passed on to the citizen-owners.
- The hospitality product becomes even more expensive. Let’s not forget that now in short term rentals the Climate Resilience Fee (CRF) is the same as in 5* hotels.
- The management model is flexible and by 2026 is not expected to yield large numbers of branches, VAT amounts and visitor charges.
- The turnover of companies will have “technically” and legally fallen so the treasury will have tax losses: in 2023, with 92% tax compliance, revenues amounted to 850 million euros.
- Healthy Greek companies are at risk of lockout, over-indebtedness and redundancies.
- The definition of ‘branch’ is an absurdity, as the provision of services is expressly prohibited on the properties themselves.
So if we’re going to do it, let’s do it right
If the real intention is to eliminate legal entities engaged in short-term rentals, let it be done clearly and efficiently: €1,800 business tax per property.
That way, they’ll shut down immediately, political cronies will roam the ministries undisturbed, hoteliers will enjoy the absence of competition, the state will cover the “black hole” of OPEKEPE, and the government will once again sell the narrative that short-term rentals are to blame — not its inability to tackle inflation and low wages. What more could one expect in a country where it’s always someone else’s fault?
Except there’s still Justice — and citizens — who, eventually, return to the ballot box.
* Stathis Karopoulos holds the position of Director of Stama Greece and has over 14 years of experience in the tourism industry
