Pursuant to the provisions of paragraph 1 of Article 111 of Law 4446\/2016 (Government Gazette A\u2019 240) regarding regulations for the short-term rental of properties within the framework of the sharing economy, a short-term rental is defined as the lease or sublease of a property, regardless of whether it is listed on a digital platform within the framework of the sharing economy or not, and regardless of whether the contract is concluded through the digital platform, for a specific period of less than sixty (60) days, provided that no services other than accommodation and the provision of bed linen are offered.<\/p>\n
Under the provisions of paragraph 2 of the same article and law, the possibility of short-term rental of a property through digital platforms \u2014 indicatively including Airbnb, Booking, Agoda, etc. \u2014 within the framework of the sharing economy is provided, subject, among others, to the following conditions:
\na. The property manager must be registered in the \u201cShort-Term Accommodation Property Registry\u201d maintained by the Independent Authority for Public Revenue (AADE) and must have obtained a Property Registry Number; and
\nb. Such Property Registry Number must at all times accompany the property listing and must be vsibly displayed on the digital platforms and it must be quoted or\/and displayed in every marketing listing regardless of the actual means of such promotion.<\/p>\n
By Circular E.2024\/2024, among other matters, it was clarified that the obligation to submit a Short-Term Accommodation Declaration applies to all persons acting as managers of short-term rental properties, regardless of the manner in which the relevant rents are taxed, whether as income from immovable property or as a business activity, in accordance with the provisions of Article 39A of the Income Tax Code, and regardless of whether the relevant contracts are concluded through digital platforms or not. Consequently, also for short-term rentals concluded outside digital platforms, the managers of such properties must register the property details in the Short-Term Accommodation Property Registry, obtain a Short-Term Accommodation Property Registry Number, and subsequently submit Short-Term Accommodation Declarations.<\/p>\n
The short-term rental of a property without prior registration in the Short-Term Accommodation Property Registry, regardless of whether it is concluded through a digital platform or by any other means, entails the risk of the imposition of an administrative fine equal to fifty percent (50%) of the income obtained from short-term rental after 1 January 2025, which may not be less than \u20ac20,000 (Twenty Thousand Euros). Indeed, if, following the imposition of the sanction referred to in the preceding sentence, a new violation is established within the same tax year, a fine may be imposed equal to the amount of the rents collected from the previous audit until the new audit, which may not be less than \u20ac40,000 (Forty Thousand Euros).<\/p>\n
In the event of exploitation of a property by a new manager or new owner, the re-registration of the property in the Short-Term Accommodation Property Registry and the obtaining of a new AMA are required.<\/p>\n
By virtue of paragraph 1 of Article 29 of Law 5162\/2024 (Government Gazette A\u2019 198), a new paragraph 2A was added to Article 111 of Law 4446\/2016 (Government Gazette A\u2019 240), pursuant to which it was provided, among other matters, that from 1 January 2025 until 31 December 2026 (following an extension of the initial term by virtue of Ministerial Decision No. 225\/\/2025 of the Ministry of Foreign Affairs\/ Government Gazette B 7200\/2025), first-time registration in the Short-Term Accommodation Property Registry is not permitted for properties located in the 1st, 2nd and 3rd Municipal Districts of the Municipality of Athens. This substantially means that apartments situated within the restricted areas will not be able to be rented for short term rentals.<\/p>\n
A reasonable question therefore arises as to whether new owners of properties, following a relevant sale and purchase transaction, located in the restricted geographical areas \u2014 namely the 1st, 2nd and 3rd Municipal Districts of the Municipality of Athens \u2014 and which already have an Airbnb licence, may or may not request their registration in the Short-Term Accommodation Registry despite the above-mentioned restrictions.<\/p>\n
According to Circular No. Protocol E2049\/21.07.2025 and No. E.2\/2025 of the Independent Authority for Public Revenue regarding the management of AMA numbers and the registration of properties in the Short-Term Accommodation Property Registry, and specifically Article 10 thereof, it was clarified that \u201c…the restrictions imposed by the provisions of paragraph 2A of Article 111 of Law 4446\/2016 concern, in accordance with the above, only properties located in the 1st, 2nd and 3rd Municipal Districts of the Municipality of Athens and which had not been registered by 31 December 2024, namely properties being registered for the first time in the \u2018Short-Term Accommodation Property Registry\u2019.\u201d<\/p>\n
Consequently, properties that already had an AMA, having been registered in the Short-Term Accommodation Property Registry up to and including 31 December 2024, and which, due to a change in the person of the owner\/manager\/tenant\/subtenant, must be re-registered in the said registry in order to obtain a new registration number in the \u201cShort-Term Accommodation Property Registry\u201d, are not subject to the above prohibition on registration. Indicatively, the said clarifying circular states that an AMA is granted for the above properties in specific cases, including a change in the person of the manager as a result of transfer of the property, whether for valuable consideration or by way of gift, or due to succession.<\/p>\n