Greek Tax Representative’s Liability for Unpaid VAT

The EU General Court in Case T-356/25 (Rapera) considered whether a Greek customs/tax agent for a non-established company can be held jointly and severally liable for a large unpaid VAT debt when she only filed returns and paid assessed VAT, without keeping books or controlling the company’s transactions.
The Greek tax authority sought to recover over EUR 3.34 million in unpaid VAT from the foreign company and imposed precautionary measures on both the company and the agent.
The key legal issues concerned Articles 204 and 205 of the VAT Directive and whether national rules may automatically make a tax representative liable for VAT, even where the representative had no involvement in, or knowledge of, the taxable transactions.
The referring court also asked whether liability can depend on whether the supplies were made under the company’s Greek or Italian VAT number.

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.