Debit Note in Greece: Rules and Requirements
Businesses in Greece operate under the VAT system governed by VAT Law no. 2859/2000 (as amended) and the invoicing and accounting regime overseen by the Independent Authority for Public Revenue (AADE). A debit note is a commercial document issued by a supplier to increase the value of a previously issued invoice when goods or services were undercharged, additional charges are required, or the original invoice did not capture the full taxable supply. It applies to VAT-registered businesses in Greece and ensures that the taxable value in the VAT return corresponds to the corrected transaction.
Note: Greek VAT law provides detailed guidance on invoices and credit notes, while “debit note” terminology appears less frequently in official documentation. However, the concept exists in practice (χρεωστικό σημείωμα) and is treated as an adjustment document under general invoicing and amendment rules. This blog explains when to issue a debit note in Greece, what it should include, and how it helps stay VAT compliant.
What Is a Debit Note in Greece
A debit note is a document that a supplier issues to a buyer when an additional payment is required on a previously issued invoice because the original amount was lower than it should have been. It acts as the counterpart to a credit note (which decreases the invoice value) and serves to correct the value of a taxable supply so that the correct amount is billed and the supplier can recover the full payment owed.
In Greece, the concept of invoice adjustments is governed by the general invoicing rules under VAT Law and accounting standards. These rules require specific information on invoices and on adjustment documents. While public guidance often focuses on invoices and credit notes, the principle of issuing an adjustment to increase an invoice (i.e., a debit note or χρεωστικό σημείωμα) follows from the general requirement that the correct taxable amount must be reported and documented.
When to Issue a Debit Note in Greece
A debit note should be issued when the original invoice amount was lower than it should have been, due to reasons such as:
Errors in calculation – when the total of an invoice was added incorrectly and the buyer was billed less than the correct amount.
Missed charges – when additional costs (for example, freight, packaging, or handling) were omitted from the original invoice.
Additional goods or services – when extra products or service hours have been supplied after the original invoice date but were not included in the first invoice. If such items represent a new taxable supply, then a new invoice (or amended invoice) may be required rather than simply a debit note.
Key Details Required on a Debit Note in Greece
When issuing a debit note in Greece (or equivalent correction document), it should include the following key details (based on general invoice and adjustment requirements plus best practice):
The words “Debit Note” clearly at the top of the document (or clearly stating it is an adjustment increasing the value).
Supplier’s details – the name, address, and Greek VAT number (format EL123456789).
Customer’s details – the name and address of the customer.
Reference to the original invoice number and date – to clearly link the debit note to the correct supply.
Reason for the adjustment – e.g., underbilling, omitted freight/handling, additional service.
Description of the adjustment – a clear explanation of which goods or services are being added or adjusted.
Amounts – the additional charges and the new total payable. If VAT applies, make sure the correct VAT rate and amount are shown (and if it triggers a new supply, a new invoice may be required).
Date of issue – the date when the debit note is issued.
Identifying number – the debit note should have a unique, sequential number and must be properly archived.
If applicable: VAT rate applied, net taxable amount, and VAT amount, following Greece’s invoice requirements.
Scenarios Where Debit Notes Are Used in Greece
Here are some typical situations in Greece where a business might issue a debit note:
Freight or handling charges omitted – Suppose the supplier issued an invoice for goods but did not include an agreed packaging or transport charge. After discovery, the supplier issues a debit note to increase the amount due.
Service extension – If additional hours of service were provided beyond what the original invoice covered and those additional hours were not documented originally, a debit note can be used to capture the extra fee (provided it is not treated as a completely separate taxable supply requiring a new invoice).
Under-billing – If, due to human error, the price of goods or services was entered lower than the agreed price and the supplier needs to recover the shortfall, a debit note lets the supplier adjust the original billing.
Extra goods supplied after the invoice date – If extra goods were delivered after the original invoice, the supplier may issue a debit note (unless the best practice in Greece is to issue a new invoice for the additional supply).
In each case, the business must ensure that its VAT return reflects the increased taxable value in the period when the debit note is issued (or when the correct taxable value arises). Greece’s VAT rules emphasize correct reporting of output VAT and input VAT in the right period.
Record Keeping and Audit Requirements in Greece
In Greece, suppliers must retain complete and accurate records of invoices and related documents (including all debit and credit adjustments) for audit and compliance purposes. Invoices and their related documents must be retained for a minimum of five years, although rules or exceptions may exist permitting even longer holdings. Businesses should:
Link the debit note to the original invoice to ensure traceability.
Ensure the debit note is part of the accounting books and supports the VAT return.
Maintain electronic or paper versions as per Greek invoicing and e-reporting rules. Greece’s myDATA platform requires reporting of transactional data including invoices, credit notes, and debit notes.
Ensure that any required VAT adjustment is included in the VAT return for the period when the debit note arises.
Penalties for Incorrect Issuance in Greece
In Greece, if a business does not issue an adjustment (a debit note or new invoice) as they are required to do so, or if there is a document with incorrect or missing information, the business may be subject to penalties and interest under Greece's tax regime. Failure to issue a correct invoice, or failure to provide an adjustment to that invoice, can result in substantial penalties. Penalties can be imposed for a single invoice and repeat offenses can result in increased penalties. It is important to have training for the staff and provide for an adjustment to their invoices, with proper documentation, to demonstrate compliance with the Greek VAT regime and to avoid any penalties or disputes.
Conclusion
In Greece, a debit note is a document issued to increase the value of a previously issued tax invoice in order to ensure the proper taxable amount is collected and declared within the requirements of VAT legislation. A debit note is issued for: adding further charges, correcting under-billed invoices, or correcting omitted charges. The debit note must contain the supplier and customer details, VAT numbers, reference noting the invoice the debit note relates to, the reason for the debit note, the amount + VAT (if applicable) and date of issue. Proper documentation for audit; attaching the debit note supports the original invoice; and noting the VAT period to which the amount to be collected relates, are all essential to being compliant to Greek VAT law.
FAQs
Who can issue a debit note in Greece?
Any VAT-registered business (or taxable person under Greek VAT law) can issue a debit note to correct an under-billing or add omitted charges on a previously issued invoice.What is the difference between a debit note and a credit note in Greece?
A debit note increases the payable amount of a previously issued invoice, while a credit note decreases it (for example, in case of overcharging or return of goods).Is VAT applied on debit notes in Greece?
Yes. If the adjustment involves VAT-taxable goods or services, the correct VAT rate must be applied and the VAT amount shown. If it represents a new supply rather than an adjustment, then a new invoice may be needed. Greece’s invoice rules require VAT rate and VAT amount to be shown where applicable.How long must debit notes be kept in Greece?
Debit notes (and related invoices) must be retained according to Greek record-keeping rules, generally for at least five years, with some exceptions potentially extending that period.Are electronic debit notes valid in Greece?
Yes. Electronic invoices and electronic adjustment documents are valid in Greece if they meet legal requirements. Greece operates the myDATA e-reporting platform, which requires transactional and accounting data reporting, including invoices, credit notes, and debit notes.