When you send a document without VAT to myDATA, you must also fill in the VAT exemption reason (vatExemptionCategory). You pick from the menu of VAT Code articles that provide an exemption.
Under the new VAT Code (Law 5144/2024), many article numbers changed compared with the old Code (Law 2859/2000). The myDATA code 1–31 did not change — only the label text did.
The table below summarises what each article covers so you can pick the right reason when issuing. It is not tax advice — if unsure, ask your accountant.
Who this is for
- When you issue documents without VAT to myDATA (EMDI or a provider).
- When you see an old article (e.g. 39a) in older papers and need the matching new label.
In EMDI
The field is called VAT exemption category. Set it in the myDATA mappings (yellow fields on VAT / document setup). Details: myDATA field mapping.
VAT exemption reasons table
How to read the table: the Code (1–31) is what you send to myDATA and stays the same. The Old law (Law 2859/2000) column shows the old article in the label. The New law (Law 5144/2024) column shows the new article for the same reason. The last column explains briefly when to use it. Where the two law columns match, the article number did not change.
| Code | Old law (Law 2859/2000) | New law (Law 5144/2024) | When / meaning |
|---|---|---|---|
| 1 | Without VAT – article 2 and 3 of the VAT Code | Without VAT – article 2 and 3 of the VAT Code | Scope of VAT / taxable person. Use for out-of-scope acts (e.g. compensation for material damage, income from participations, subsidies/grants) and for the Mount Athos special regime. |
| 2 | Without VAT – article 5 of the VAT Code | Without VAT – article 5 of the VAT Code | Transfer of a business as a whole, a branch or part of it (for consideration, free of charge, or as a contribution to a legal entity). Not treated as a supply of goods → no VAT. |
| 3 | Without VAT – article 13 of the VAT Code | Without VAT – article 17 of the VAT Code | Place of supply of goods outside Greece: goods already abroad at sale, assembly/installation abroad, sales on ships/aircraft/trains during an intra-EU journey, assignment of import rights, etc. |
| 4 | Without VAT – article 14 of the VAT Code | Without VAT – article 18 of the VAT Code | Place of supply of services outside Greece: e.g. consulting/accounting/legal with a customer outside Greece, services related to immovable property abroad, passenger transport outside Greece, catering abroad, admission to events abroad, electronic services with a customer outside Greece. For OSS to private customers in other Member States see also code 30. |
| 5 | Without VAT – article 16 of the VAT Code | Without VAT – article 21 of the VAT Code | Chargeability timing. When the invoice is issued later than VAT becomes chargeable and an “Special document for VAT purposes on intra-EU transactions” is issued at that earlier time. |
| 6 | Without VAT – article 19 of the VAT Code | Without VAT – article 24 of the VAT Code | Taxable amount — special cases: returnable packaging deposits; newspapers/magazines; telecom cards; tickets. |
| 7 | Without VAT – article 22 of the VAT Code | Without VAT – article 27 of the VAT Code | Domestic exemptions: medical/hospital care, social welfare, education/sports, insurance and banking, property rentals and first-home sales, supplies without VAT deduction right, sales by associations/foundations at fundraising events, etc. |
| 8 | Without VAT – article 24 of the VAT Code | Without VAT – article 29 of the VAT Code | Export outside the EU (and equivalent acts) and international transport: exports to third countries/territories outside the EU customs territory; services directly linked to exports (transport, brokerage, etc.). |
| 9 | Without VAT – article 25 of the VAT Code | Without VAT – article 30 of the VAT Code | International movement / special customs regimes: customs warehousing, customs storage, inward processing, etc. |
| 10 | Without VAT – article 26 of the VAT Code | Without VAT – article 31 of the VAT Code | Tax warehouses (not customs): supplies / intra-EU acquisitions for entry into the regime and related services; also acts inside the warehouse while goods stay in the same regime (not production/manufacture). |
| 11 | Without VAT – article 27 of the VAT Code | Without VAT – article 32 of the VAT Code | Special exemptions of article 32 other than codes 12/13: diplomacy/consulates, international organisations / EU / ECB, NATO, needs of refugees/vulnerable groups, State donors, etc. Prefer 12 for seagoing vessels; 13 for fuel/stores. |
| 12 | Without VAT – article 27 – Seagoing Vessels of the VAT code | Without VAT – article 32 – Seagoing Vessels of the VAT code | Supply/import of vessels for open-sea navigation and materials incorporated in them. Usually hull length ≥ 12 m and activity mainly on the open sea. |
| 13 | Without VAT – article 27.1.c – Seagoing Vessels of the VAT code | Without VAT – article 32.1.c – Seagoing Vessels of the VAT code | Fuel, lubricants, stores and other provisioning goods for specific vessels/craft/aircraft. More specific than 11; use with 12 for seagoing vessels. |
| 14 | Without VAT – article 28 of the VAT code | Without VAT – article 33 of the VAT code | Intra-EU supplies: goods dispatched/transported to another Member State to a taxable person (or non-taxable legal person) with a VAT number of another Member State notified to the supplier. |
| 15 | Without VAT – article 39 of the VAT code | Without VAT – article 44 of the VAT code | Small-business scheme: annual turnover (excl. VAT) for the previous and current year up to about €10,000. On documents: “without VAT – small business exemption”. |
| 16 | Without VAT – article 39a of the VAT code | Without VAT – article 45 of the VAT code | Reverse charge (VAT paid by the customer): recyclable waste; greenhouse-gas emission allowances; certain public works; mobiles, game consoles, tablets and laptops, etc. |
| 17 | Without VAT – article 40 of the VAT code | Without VAT – article 47 of the VAT code | Flat-rate schemes: coastal fishing vessels up to 12 m and sponge divers; vessels on Lake Ioannina; horse-drawn vehicles. |
| 18 | Without VAT – article 41 of the VAT code | Without VAT – article 48 of the VAT code | Farmers special scheme: e.g. agricultural supplies/services under about €15,000 and subsidies under about €5,000 in the previous year. They do not charge VAT on their supplies. |
| 19 | Without VAT – article 47 of the VAT code | Without VAT – article 54 of the VAT code | Investment gold: supply / intra-EU acquisition / import; and brokerage acting in the name and on behalf of another on investment-gold supplies. |
| 20 | VAT included – article 43 of the VAT code | VAT included – article 50 of the VAT code | Travel agents (margin): VAT only on the agency’s gross margin and only for the part of the trip within the EU — not on the full package price. |
| 21 | VAT included – article 44 of the VAT code | VAT included – article 51 of the VAT code | Manufactured tobacco: taxable amount = retail price excl. VAT. Tax is embedded in the price; indication “VAT not deductible”. |
| 22 | VAT included – article 45 of the VAT code | VAT included – article 52 of the VAT code | Dealers in used goods / works of art / collectors’ items / antiques: VAT on the resale margin (gross profit). |
| 23 | VAT included – article 46 of the VAT code | VAT included – article 53 of the VAT code | Auction sales: special taxable-amount rules (usually on the organiser’s commission/margin). |
| 24 | Without VAT – article 6 of the VAT code | Without VAT – article 8 of the VAT code | Supplies of immovable property that are not taxable acts (e.g. buildings permitted before 1.1.2006) and supplies under VAT suspension. |
| 25 | Without VAT – POL.1029/1995 | Without VAT – POL.1029/1995 | Supplies to Duty-Free Shops (KAE): a KAE exemption duplicate voucher is required; the supplier’s document must show the related exemption indication. |
| 26 | Without VAT – POL.1167/2015 | Without VAT – POL.1167/2015 | EDDA procedure: purchase/import of goods for export or intra-EU supply and related services. The buyer/importer issues a Special Duplicate VAT Exemption Voucher to the supplier or Customs. |
| 27 | Other VAT Exceptions | Other VAT Exceptions | Only if no other reason fits. Use carefully — almost all cases are covered by codes 1–26 and 28–31. |
| 28 | Without VAT – article 24 para. b’ par.1 of the VAT Code, (Tax Free) | Without VAT – article 29 para. b’ par.1 of the VAT Code, (Tax Free) | Tax Free retail to travellers: goods in personal luggage; traveller not established in the EU; goods leave the EU before the end of the third month after the month of supply. |
| 29 | Without VAT – article 47b, of VAT code (OSS non-EU regime) | Without VAT – article 56 of the VAT Code (OSS non-EU regime) | OSS non-Union: non-EU established service providers to non-taxable persons in Greece or another Member State; VAT number with prefix “EU”. |
| 30 | Without VAT – article 47c, of the Code VAT (OSS EU status) | Without VAT – article 57 of the VAT Code (OSS EU status) | OSS Union: intra-EU distance sales, supplies via electronic interfaces, and services by an EU-established taxable person not established in the Member State of consumption — mainly e-shop to private customers in other Member States and B2C services taxed in another Member State. |
| 31 | Without VAT – article 47d of VAT Code (IOSS) | Without VAT – article 58 of the VAT Code (IOSS) | IOSS: distance sales of goods imported from third countries/territories in consignments with intrinsic value up to €150 (excluding excise goods); VAT number with prefix “IM”. |
Tips
- The code (1–31) stays the same; do not renumber EMDI mappings only because the article in the label changed.
- For seagoing vessels prefer 12; for fuel/stores 13; keep 11 for the other special exemptions of the same article.
- Avoid code 27 (Other VAT Exceptions) if a more specific reason exists.
- For Tax Free, code 28 is usually used.
- For services to private customers in other Member States via OSS, see code 30 (not only code 4).