As is known from 1-2-2023 it is mandatory to file an appeal electronically through a special application. This development is clearly welcome and accelerates and facilitates the filing process, however, we identify the following:

a/ No electronic copy of the document of the appeal that was filed is exported, as is the case, for example, in the digital filing of an appeal before the Administrative Court, but only an electronic protocol - proof of filing - is produced that mentions the contested acts.This lack is particularly critical as it was decided by the Council of State in 1686/2019 that the content - the grounds of the judicial appeal - must in principle be identical to the content of the appeal. But how does the applicant establish and prove the exact content of the appeal that he uploaded as an attachment to the application of the AADE? It is proposed that, in addition to the export of the record, a copy of the electronically filed appeal be exported.

b/ The size limit of 10 MB for each attachment is very small. What happens if there are many large files? A technical solution must be provided or else the applicant will be forced to send his relevant documents by USB/CD when they are supposed to be sent electronically.

c/ The appeal is filed with the applicant's taxis codes and the attached file of the appeal must also have a digital attestation - signature of the applicant from gov.gr. It is an inflexible process as there are persons who are not familiar with the technology and or do not have data certification and or cannot do digital attestation of document. It should be explicitly provided for the parallel possibility of filing with codes and digital signature of an authorized person, e.g. a lawyer or even an accountant, who in practice - for the most part - undertakes the drafting and filing of the appeal anyway and often receives the client's disbelief to hand over his taxis codes to file the appeal.