Petros Pantazopoulos


Petros Pantazopoulos

Partner

Petros joined the firm in 2006 and is a partner

He is the Head of the Firm’s tax and administrative law practice.

A recognized tax attorney, with extensive experience in tax and customs litigation and out-of-court dispute resolution, Petros has pleaded for numerous of cases before the Supreme Administrative Court (Council of State) and the Administrative Courts.

Petros advises several domestic and foreign entities and private clients on direct and indirect tax matters and on administrative (tax, customs) and court procedure.

He assists clients to develop strategies related to tax and customs audits and negotiates with tax and customs authorities in connection with both out–of–court and judicial settlements.

Recent highlights of his work include:

Represented a major Greek Bank in relation to its claims against Greek Tax Authorities for the refund of tax that has been withheld on interest accrued, among others, on bonds.

Represented a major gambling company in relation to its dispute with the tax authority for the alleged receipt of fictitious invoices.

Represented the Church of Scientology with regard to its dispute against Greek Tax Authorities in connection with the assessment of Special Property Tax.

Represented a major cement company with regard to the unlawful imposition of surcharges following a final court decision.

Represented two major multinational companies before the competent courts in connection with the imposition of stamp duties’ fines on cash pooling transactions.

Represented a major Greek Bank before the Council of State with regard to a dispute in connection with the imposition of transaction tax on the sale of listed stocks.

Represented the Hellenic Republic Asset Development Fund (HRADF) before the Council of State in connection with the procedure with regard to the privatization process for the grant of the exclusive right to organize and conduct mutual betting on horses races in Greece.

Besides his native Greek, Petros speaks English and German.

Education

  • National & Kapodistrian University of Athens School of Law – Post-doctoral Researcher in Tax Law, 2022
  • National & Kapodistrian University of Athens School of Law – Ph.D. in Tax Law, 2010
  • National & Kapodistrian University of Athens School of Law – LL.M. in Public Law, 2002
  • National & Kapodistrian University of Athens School of Law – Law Degree (Ptychion), 2000

Publications

  1. Books
  • The procedural law of tax disputes, Athens 2023.
  • The juristiction of the administrative Court on tax disputes, Athens 2022.
  • Peter H.J. Essers (ed.), History and Taxation: The Dialectical Relationship between Taxation and the Political Balance of Power, IBFD, 2022.
  • Th. Fortsakis – A. Tsourouflis, Tax Law, 7th ed. 2022. Also, a member of the editorial team of the previous six editions.
  • (With Κ. Sideromemou) Guide to FATCA and CRS Compliance, LexisNexis 2020 (editing of Chapter about Greece).
  • (With Prof. Th. Fortsakis) “Administrative Law Procedure” 15th edition, Athens 2020. Also, a member of the editorial team of the previous fourteen editions.
  • I. Fotopoulos (ed.), Tax Procedure, Athens 2018.
  • (With E. Bakalis), Tax Procedure, 2nd ed., Athens 2018. Also, a member of the first edition, 2016.
  • H. Cryssanthakis, Interpretation of the Code of Administrative Law Procedure”, 3rd ed., Athens 2018. Also, a member of the previous two editions.
  • Greek Law Digest, Athens 2018.
  • P. Marinakis (ed.), Competence of Administrative Courts, Athens 2018.
  • R. Seer (ed.), Surcharges and penalties in Tax Law, IBFD 2016.
  • (With Prof. Th. Fortsakis) “Tax Law Legislation”, 5th edition, Athens 2014.
  • Member of the editorial team of the “Greek Law Dictionary – Volume II, Public Law”, Athens 2014.
  • Member of the editorial team of “Interpretation of the Code of Administrative Law Procedure”, Athens 2014.
  • The Constitutional borders of a tax audit, Athens 2012.
  • (With Judge P. Marinakis) “Administrative Procedural Law”, two editions, Athens 2011 and 2009.
  • Member of the editorial team of the law collection “Tax Law Legislation” (ed. T. Fortsakis – I. Fotopoulos), 6th Edition, Athens 2012. Also, a member of the editorial team of the previous five editions, Athens 2004, 2006, 2007 and 2008, 2010.
  • Co-contributor in the collective work “Substantive and procedural administrative law”, 2009 (chapter of taxation).
  • Member of the editorial team of the “Code of Income Taxation”, Athens 2009.
  • Member of the editorial team of the third edition of “Tax Law” (ed. T. Fortsakis), Athens – Komotini 2008 (chapter of indirect taxation).
  • Member of the editorial team of the “Code of Books and Records”, Athens 2007.
  • Co-contributor in the collective work “Applications of commercial law”, Athens 2007 (chapter of a joint account).
  • (With Prof. H. Chryssanthakis), “Reports on Constitutional Law” Athens 2007.
  • (With Prof. H. Chryssanthakis) “Reports on Administrative Law” Athens 2006.

2. Articles

  • The control of procedural formulas in the case of a tax appeal, Advocate (Greek Law Bulletin), v. 153/2022, p. 42.
  • Tax ruling – Comperative overview in EU, Theory and Praxis of Administrative Law (Greek Law Bulletin), 2022, p. 874.
  • A Critical Approach on the Greek Implementation of the DAC6 (with Κ. Kalampaliki, Intertax, Vol. 50/2022, p. 543.
  • The principle of retroactive application of the most favourable law in the field of tax penalties, Theory and Praxis of Administrative Law (Greek Law Bulletin), 2022, p. 494.
  • Issues and developments concerning the impact of bank account data on the tax audit process, Enterprise (Greek law bulletin) 2021, p. 231.
  • Tax imputation and limitation – A relationship in constant evolution, Public Law Applications (Greek law bulletin), 2021, p. 36.
  • The Impact of the Transposition of the ATAD on the Greek Tax System (with K. Kalampaliki, Intertax, Vol. 48/2020 p. 233.
  • The concept of permanent establishment – Content and basic concepts – The differences between direct and indirect taxation, Enterprise (Greek law bulletin) 2020, p. 341.
  • The tax statute of limitations again guarantees legal certainty, Advocate (Greek Law Bulletin), v. 122/2017, p. 35.
  • Joint liability of directors of legal persons for the debts of the company before and after the Code of Tax Procedure, Administrative Trial (Greek law bulletin) 2016, p. 217.
  • The impact of the out of court procedure on tax disputes – Successful measure or further delay in dispute resolution – Is arbitration the solution?, Theory and Praxis of Administrative Law (Greek Law Bulletin), 2016, p. 194.
  • The possibility of retroactive application of Articles 15 par. 3 of Law 3888/2010 and 48 par. 3 of Law 2238/1994 in the case of an audit due to an increase in property, Business and Company Law (Greek law Bulletin), 2015, p. 221.
  • Administrative tax penalties under the Code of Tax Procedure, Theory and Praxis of Administrative Law , 2014, p. 223.
  • Compatibility with the ECHR of the limitations of the legal professional privilege by the legislation against money laundering, Business and Company Law (Greek law bulletin) 2013, p. 222.
  • The extension of the subscription period of tax disputes, Enterprise (Greek law bulletin) 2012, p. 863.
  • The treatment by the administrative courts of the procedure for the punishment of customs duty offenses (CoS Decision No 2067/2011), Theory and Praxis of Administrative Law, 2011, p. 1100.
  • Tax reform 2010 – The proposals of the Athens Bar Association on the restructuring of the tax administration, Enterprise (Greek law bulletin) 2010, p. 270.
  • The Handbook of a tax audit, Enterprise 2008, p. 1332 & 1453 and 2009, p. 21.
  • The new Handbook of a tax audit, Advocate (Greek law bulletin), issue March-April 2008.
  • The right of hearing in the tax procedure. The course of the right through theory and case law, Theory and Practice of Administrative Law (Greek law bulletin) 2008, p. 1026.
  • The interest of claims of suppliers of the Greek Armed Forces, Defence Procurement Law Bulletin, issues 3/2008, p.2.
  • The audit of tax objects, Enterprise 2006, p. 1312.
  • The new Law 3453/2006 – Changes in the taxation regime of associated enterprises and the procedure of administrative contribution between EU members in the field of taxation (in Greek), Advocate 2006, p. 14.
  • Prohibition of discriminations in free movement of capital. Based on the decision of the Greek Council of State decision 2393/2004, Enterprise 2004, p. 824
  • Fictitiousness of tax records and burden of proof according to the recent precedents of administrative courts, Advocate 2004, p. 210.
  • A special tax on the real estate of off-shore enterprises, Business and Company Law 2003 p. 709.
  • The new system of tax audits and calculation of income, Advocate 2003, p. 74.
  • Tax sanctions and European Convention on Human Rights, Business and Company Law 2003, p. 255.

Petros is also a frequent speaker on issues of Greek tax law.

Teaching Posts

Scientific collaborator in the field of tax law at the Law School of the University of Athens
Lectured at the Law School of the University of Athens and the Law School of the University of Thessaloniki

Bar Admissions

Member of the Athens Bar Association since 2002. Qualified to practice before the Supreme Court.

Contact Petros Pantazopoulos

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