
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 and an Assistant Professor of Tax and Fiscal Law at the Law School of the Aristotle University of Thessaloniki.
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.
Petros is a frequent speaker at conferences and seminars on all tax subjects. He has authored three monographs and has participated in the writing of many works and studies on tax, fiscal and administrative law. He also participates in the Scientific Council of the Association of Listed Companies, in the Scientific Committee of the several legal journals, as well as in the Boards of the Greek Branch of the IFA and the Hellenic Society for Tax Law and Fiscal Studies.
Recent highlights of his work include:
- Represented a major telecommunication’s company in relation to a dispute with the Greek State regarding the imposition of a financial charge on the services. .
- Represented a major food company in relation to its dispute concerning its intra-group transactions.
- Represented a shipping company with regard to its dispute with the Tax Authority in relation to a Special Property Tax assessment.
- 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 multinational company before the competent courts in connection with its dispute with the Tax Authority on the deduction from the company’s gross revenues of certain amounts which corresponded to commitment fees and debit interests paid within the framework of agreements entered into between affiliated companies.
- Represented a tech bank before the competent courts in connection with its dispute with the Tax Authority in relation to its obligation to withhold tax on payments made to cloud computing platforms.
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
Books (in reverse chronological order)
- The procedure of tax disputes – The rules for their procedural and judicial resolution (second edition), 2024.
- The power of the administrative judge in tax disputes – A contribution to the interpretation of Article 79 para. 5 L. 2717/1999, (post-doctoral research), 2022.
- The constitutional limits of tax control (doctoral thesis), 2012.
Books in cooperation (in reverse chronological order)
- Th. Fortsakis – A. Tsourouflis, Tax Law, 8th ed., Nomiki Vivliothiki, Athens, 2024, p. 682.
- Χ. Chrysanthakis (ed.), Administrative Procedure – Volume 1 (Interpretation by Article), Nomiki Vivliothiki, 4th ed., Athens 2023, p. 171.
- Peter H.J. Essers (ed.), History and Taxation: The Dialectical Relationship between Taxation and the Political Balance of Power, IBFD, 2022, p. 786.
- Th. Fortsakis – A. Tsourouflis, Tax Law, 7th ed., Nomiki Vivliothiki, Athens, 2022, p. 682.
- Th. Fortsakis, A. Tsourouflis, K. Savvaidou, P. Pantazopoulos, Tax Law, Nomiki Vivliothiki, Athens, 6th ed., 2021, p.680.
- Collective Work, Entrepreneurship and taxation, Nomiki Vivliothiki, Athens, 2021, p. 144.
- Collective Work, Guide to FATCA and CRS Compliance, LexisNexis 2021, pp. 2120.
- Th. Fortsakis – P. Pantazopoulos, Administrative Procedure, 15th ed., Nomiki Vivliothiki, Athens, 2020, p. 1840. Also, member of the editorial team of all the previous fourteen editions.
- Χ. Chrysanthakis, Recommendations on Constitutional Law, 2η ed. 344. Collaboration, also in 1st ed., Nomiki Vivliothiki, 2007.
- Χ. Chrysanthakis (ed.), Administrative Court of First Instance, Nomiki Vivliothiki, 2η ed., Athens 2018, p. 964.
- Ι. Fotopoulos (ed.), Tax Procedure, Sakkoulas, Athens-Thessaloniki, 2018, p. LXXVIII + 2205.
- P. Pantazopoulos – E. Bakalis, Tax Procedure, 2nd edition, Nomiki Vivliothiki, Athens 2018. Also member of the author’s team of the first edition, Nomiki Vivliothiki, 2016.
- Th. Fortsakis (ed.), Examples of Tax Law, 2η ed., Nomiki Vivliothiki, Athens 2018, p. 704. Member, also, of the editorial team of 1ης ed.
- Χ. Chrysanthakis (ed.), Interpretation of the Code of Administrative Procedure, 3η ed., Nomiki Vivliothiki, Athens 2018, p. Also, member of the previous two editions, Nomiki Vivliothiki, Athens 2015, 2014.
- Collective Work, Greek Law Digest, Nomiki Vivliothiki, Athens 2018, p. 728.
- P. Marinakis (ed.) Jurisdiction and Competence of Administrative Courts, Nomiki Vivliothiki, Athens 2017, p. 414.
- R. Seer (ed.), Surcharges and penalties in Tax Law IBFD 2016, pp. 854 (with Professor Th. Fortsakis).
- Χ. Chrysanthakis, Recommendations on Administrative Procedural Law, Nomiki Vivliothiki, Athens 2014, p. 256.
- Th. Fortsakis – P. Pantazopoulos, Tax Legislation, 5th edition, Nomiki Vivliothiki, 2014, p. 914.
- Χ. Politis H., E. Spiliotopoulos, Dictionary of Legal Terminology II – Public Law, Nomiki Vivliothiki, Athens 2014, p. 956.
- P. Marinakis, P. Pantazopoulos, Administrative Procedural Law – Interpretative Comments – Case Law by Article, 7th ed., Nomiki Vivliothiki, Athens, 2011, p. 1.344. Contribution also to the 6th ed., Nomiki Vivliothiki, Athens, 2009.
- Χ. Chrysanthakis, Applications of Administrative Substantive and Procedural Law, Nomiki Vivliothiki, Athens 2009, p. 800.
- Th. Fortsakis, Tax Law, ed. Nomiki Vivliothiki, Athens – Komotini, 3rd ed., 2008, p. 680.
- Th. Fortsakis, H. Chrysanthakis, Administrative Legislation, Nomiki Vivliothiki, 2008, p. XXVIII and 1575.
- G. Triantafyllakis (ed.), Applications of Commercial Law, Nomiki Vivliothiki, Athens, 2007, p. 1584.
- Χ. Chrysanthakis, Recommendations on Constitutional Law, Nomiki Vivliothiki, Athens, 2007, p. 344.
- Χ. Chrysanthakis, P. Pantazopoulos, Administrative Law Recommendations, 2nd ed., Nomiki Vivliothiki, Athens 2006, p. 206.
Articles (published in scientific journals, in reverse chronological order)
- Illegal State Aid and Profit Sharing In Apple’s Irish Branches (Tax Notes International, March 3, 2025, p. 1391).
- Taxation as a means of protection of the environment – editing of a special tribute (Environment and Law, 2024, pp. 473).
- The minimum economic substance criterion of the proposal for a Directive on the prevention of abuse of dummy entities for tax purposes (“ATAD 3”) in the light of cross-border employment of workers – Issues and uncertainties (EDPS, 2023, pp. 12-18).
- The Extrajudicial Tax Dispute Resolution Committee – A tool to speed up the resolution of tax disputes or a “constant” diversion from the system of resolving such disputes? (Enterprise, 2023, pp. 767 – 769).
- The regulatory framework for dealing with money laundering – Obligations and risk exposure of accountants and tax advisors (Enterprise, 2023, pp. 666 – 672).
- The acts and omissions challenged in the extrajudicial tax appeal (Enterprise, 2023, p. 405).
- Boundaries of Legal Professional Privilege Under DAC6 (Tax Notes International, March 20, 2023, p. 1671).
- The budget of the European Union: the role of fiscal harmonisation between Member States in achieving its objectives (Theory and Practice of Administrative Law 2023, p. 216).
- The control of procedural formulas in the case of a tax appeal (Advocate, Vol. 153/2022, pp. 42 – 45).
- Tax Rulings – A comparative overview within the EU (Administrative Law Theory and Practice, 2022, pp. 874 – 879).
- A Critical Approach on the Greek Implementation of the DAC6 (with K. Kalampaliki, Intertax, Vol. 50, No 6-7, 2022, pp. 543 – 555).
- The principle of retroactive application of the most favourable law in the field of tax penalties (Theory and Practice of Administrative Law, 2022, pp. 494 – 502).
- Issues and developments regarding the impact of bank account data on the tax audit process (Enterprise, 2021, pp. 231 – 237).
- Tax imputation and limitation period – A relationship in constant evolution (Public Law Applications, 2021, pp. 36 – 40).
- The Impact of the Transposition of the ATAD on the Greek Tax System (with K. Kalampaliki, Intertax, Vol. 48, No 2, 2020, pp. 233 – 249).
- The concept of permanent establishment – Content and basic concepts – The differences between direct and indirect taxation (Enterprise, 2020, p. 341 – 345).
- The tax statute of limitations again guarantees legal security (Advocate, vol. 122/2017, pp. 35 – 38).
- Payment of a fee on appeals and remedies in administrative disputes of substance (Advocate, vol. 120/2017, pp. 38 – 40).
- Personal liability of directors of legal entities for the debts of the company before and after the Code of Tax Procedure (Administrative Law, 2016, pp. 217 – 223).
- Legal developments in tax law issues. The impact of the appeal procedure on tax disputes – Successful measure or further delay in dispute resolution – Is arbitration the solution? (Theory and Practice of Administrative Law, 2016, pp. 194 – 198).
- Capital gains – Retroactivity (with Professor Th. Fortsakis, Bulletin of Tax Legislation, 2016, p. 221 – 234).
- 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 (with Prof. Fortsakis, Business and Corporate Law, 2015, p. 481 – 484).
- The character of the regulation on the taxable “increase of property” as a substantive provision (Bulletin of Tax Legislation, 2015, pp. 1198 – 1216).
- A short guide to lodging an appeal in tax cases (Enterprise, 2014, p. 1072 – 1076).
- Administrative sanctions for violations of tax legislation under the Tax Procedure Code (Theory and Practice of Administrative Law, 2014, pp. 223 – 230).
- The ECtHR judgment in Michaud v. France – Compatibility with the ECHR of the restrictions on legal professional privilege under anti-money laundering legislation (Business and Company Law, 2013, pp. 222 – 231).
- Limitation of the obligation to co-sign tax returns by an accountant – The decision no. 2445/2012 of the Council of State (Advocate, vol. 95/2013, pp. 34 – 36).
- The extension of the limitation period in tax cases (Enterprise, 2012, p. 867 – 875).
- The treatment by the administrative courts of the punishment procedure for smuggling – On the occasion of the Council of State’s decision 2067/2011 (Theory and Practice of Administrative Law, 2011, pp. 1100 – 1115).
- Tax Reform 2010 – The proposals of the Athens Bar Association on the issue of the reorganization of the Ministry of Finance (Business, 2010, pp. 270 – 276).
- Closure of pending tax cases and regulation of overdue debts under Law 3888/2010 (Advocate, vol. 81/2010, pp. 76 – 78).
- The changes in the tax invoice after Law 3842/2010 (Advocate, vol. 80/2010, pp. 72 – 73).
- Facilities for overdue debts to the State (Advocate, Vol. 79/2010, pp. 86 – 87).
- Tax Audit Manual (Enterprise, 2008, p. 1332 – 1336 and 1453 – 1458 and Enterprise, 2009, p. 21 – 26).
- The new tax audit manual (Advocate, vol. 66/2008, pp. 84 – 86).
- The prior hearing of the person concerned in the tax procedure. The development of the right through theory and case law. Legal and administrative developments and perspectives (Theory and Practice of Administrative Law, 2008, pp. 1026 – 1030).
- The control of tax objects – Types and Instruments (Enterprise, 2006, p. 1457 – 1468).
- The new law 3453/2006 – Changes in the tax regime of associated companies and in the administrative assistance procedure between Member States in the field of taxation (Advocate, Vol. 54/2006, pp. 14 – 15).
- Non-discrimination in the free movement of capital. On the occasion of Council of State’s decision 2393/2004 (Enterprise, 2005, p. 824 – 830).
- Virtuality of tax data and burden of proof according to the recent jurisprudence of the administrative courts, on the occasion of the Council of State’s decision 1553/2003 (Advocate, 2004, p. 210 – 211).
- The new system of tax control and income determination – Presentation and criticism (Advocate, 2004, pp. 74 – 76).
- Tax sanctions and the European Convention on Human Rights (Business and Company Law, 2003 p. 255 – 264).
Teaching Posts
- Assistant Professor at the Law School of the Aristotle University of Thessaloniki (AUTh)
- 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.

