Following the issuance and notification to the taxpayer of the final corrective tax determination acts and fine imposition acts, the taxpayer has the right to submit an administrative appeal, requesting the reexamination of the acts they dispute, in the context of an administrative procedure, by the Directorate of Complaints Settlement of the Tax Administration, in accordance with the provisions of article 63 of the Tax Procedure Code (Law 4987/2022). The request is submitted to the tax authority that issued the act, within sixty (60) days of the notification of the act to the foreign resident taxpayer and must state the reasons and documents on which the latter bases the request of reexamination.

Furthermore, against the decision or tacit rejection of the appeal by the Dispute Resolution Department, the taxpayer may within ninety (90) days appeal to the competent administrative court in accordance with the Administrative Procedure Code (Law 2717/1999), the decision of which is binding for the Tax Administration. A direct appeal to the administrative courts against any act of the tax authority, for which an administrative appeal must be filed, is inadmissible.