Greece incorporates EU rules on mandatory disclosure of cross-border tax planning structures, exit taxation, hybrid mismatches, alternative tax dispute resolution and the VAT quick fixes directive

On July 29 the Greek Parliament passed a comprehensive tax bill, which incorporates into national law certain international tax and VAT related EU directives. These are aimed at promoting tax transparency, by establishing the mandatory disclosure of potentially tax aggressive cross-border structures, helping to level the playing field on international taxation matters, by discouraging certain international operation structures that enable double non-taxation, and improving tax certainty and fairness, by introducing a thorough framework of alternative dispute resolution proceedings  as well as simplifying certain VAT rules concering the intra-EU trade.

Specifically, the following directives are incorporated into Greek tax law:

  1. DAC6 (EU Council Directive 2018/822) on mandatory disclosure of cross-border arrangements presenting features that indicate a potential risk of tax avoidance and the related directive 2020/876 on the deferral of the disclosure deadlines due to the COVID-19 pandemic
  2. ATAD I, as regards its exit taxation rules for an entity’s transferred assets outside a Member State’s jurisdiction (in specific article 5 of EU Council Directive 2016/1164. The other provisions of this directive have already been transposed into Greek law with Law 4607 of 2019)
  3. ATAD II (EU Council Directive 2017/952) regarding hybrid mismatches)
  4. The EU Dispute Resolution Directive (EU Council Directive 2017/1852 on tax dispute resolution mechanisms in the European Union)
  5. The VAT quick fixes (EU Council Directive 2018/1910) and improvements to the taxable amount provision relating to supplies between related parties

For more details, you may refer to our tax alert below: