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GloBE Country Guide: Greece

Summary

Status Enacted Law
LawAADE A.1236 (domestic top-up tax) and A.1237 (IIR/UTPR), dated 30 October 2026 and published/effective 2 November 2026, prescribe separate self-assessment returns under the existing law. Analysis.

On April 5, 2024, Law 5100/2024 was published in the Official Gazette. This implements the EU Minimum Tax Directive in Greece from December 31, 2023 (with the UTPR applying from December 31, 2024).

On February 22, 2024, the Ministry of National Economy and Finance issued a draft law to implement the EU Minimum Tax Directive
Effective DateAccounting periods beginning on or after December 31, 2023
IIRYes (2024)
UTPRYes (2025)
QDMTTYes (2024)
Filing DeadlinesSelf-assessment: A.1236/A.1237 article 4 sets the last working day of the month following the month of the GIR deadline; payment is due the last working day of the following month after that self-assessment deadline (article 6). Nil returns are required. These returns are separate from the GIR; no general extension is introduced.

Standard. Transitional rule: AADE Decision A.1131/2026, Article 5(1)–(2) (Gazette B 3921, June 29, 2026) extends GIR filing to October 30, 2026 for MNE groups and large domestic groups with reporting fiscal years ending on or before March 31, 2025. The Article 48(4) notification deadline for MNE groups in that same cohort is also October 30, 2026.
Safe HarboursTransitional CbCR Safe Harbour, QDMTT Safe Harbour and the Transitional UTPR Safe Harbour.

Contents
  1. Legislation
  2. General
  3. Differences to Model Rules
  4. Qualifying Domestic Minimum Top-Up Tax
  5. Administration and Filing
  6. Penalties

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