GREECE Law and Practice Contributed by: John C. Dryllerakis, John Papadakis and Nikos Kalantzis, Dryllerakis Law Firm
Reporting of cross-border arrangements (DAC6/ EU Mandatory Disclosure Rules) Intermediaries and taxpayers must disclose certain cross-border transactions that meet specified “hall - marks” indicative of potential tax avoidance. Greece implements the EU Directive 2018/822 (DAC6), requir - ing disclosure within 30 days of the arrangement being made available, ready for implementation or first executed. Mandatory Reporting of Financial Accounts and Beneficial Ownership Automatic exchange of financial account information Greece participates in the Automatic Exchange of Financial Account Information (AEOI) under the Com - mon Reporting Standard (CRS). Financial institutions report account balances, interest, dividends and other income earned by non-residents to the Greek authori - ties, who then exchange this information with other jurisdictions. Beneficial ownership register Greek legal entities must report beneficial owner - ship information to the national registry. This enables authorities to trace ultimate owners and detect poten - tial schemes designed to obscure tax liabilities. 5.5 Role of Tax Authorities and Enforcement Measures Greek tax authorities are empowered with comprehen - sive investigative tools, including access to records, audits (desk and field), unannounced inspections and, in serious cases, judicially authorised searches and raids. These powers are complemented by cross- border information exchange and mandatory report - ing frameworks, thereby ensuring a robust system for detecting tax fraud, evasion and abusive arrange - ments. Access to Accounting Records and Documentation Tax authorities have the right to request and exam - ine all accounting records, financial statements and supporting documentation of taxpayers. This includes invoices, contracts, bank statements and electronic records. Records must be provided in the format and
guarding against cross-border tax abuse involving high-risk or preferential jurisdictions. In addition to the domestic list, Greece, as an EU Member State, also applies the EU list of non–coop - erative jurisdictions for tax purposes compiled by the Council of the European Union. This EU list identifies jurisdictions that fail to meet minimum standards on tax transparency, fair taxation and measures against base erosion and profit shifting (BEPS). 5.4 Reporting Obligations and Disclosure Regimes Greece maintains a wide framework of mandatory reporting obligations for taxpayers and intermediar - ies, designed to enhance transparency, prevent tax abuse and detect both domestic and cross-border tax fraud. These obligations complement the crimi - nal and civil penalties for tax evasion and the general anti-abuse rules provided under the Greek Income Tax Code (Law 4172/2013) and the Code of Tax Procedure (Law 5104/2024). Tax Return Filing and Financial Reporting Annual tax returns must be filed by all individuals and legal entities resident in Greece, reporting all income, profits, capital gains and deemed income. Financial statements prepared under Greek Account - ing Standards are submitted for corporate taxpay - ers and tax adjustments are disclosed to reconcile Greek taxpayers engaging in related-party transac - tions must maintain master files and local files dem - onstrating compliance with the arm’s-length principle. These documents must be submitted to tax authori - ties upon request. Country-by-country reporting (CbCR) Large multinational enterprises with consolidated revenue exceeding EUR750 million must file CbCR reports with the Greek Tax Administration, providing detailed information on income, taxes paid and eco - nomic activity by jurisdiction. accounting profits with taxable income. Cross-Border Reporting Obligations Transfer pricing documentation
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