Katerina Batsika

Our September Tax Briefing analyzes recent developments in tax legislation.

Our August 2026 Tax Briefing analyses Important Decisions by the IAPR and the Council of State.

Our July 2026 Tax Briefing analyses the Alternative Taxation of Foreign‑Source Income for Individuals Transferring their Tax Residence to Greece.

On 24 June 2026, the European Commission adopted an ambitious tax simplification package comprising two legislative proposals aimed at simplifying EU tax rules, reducing compliance burdens for businesses and strengthening the competitiveness of the Internal Market.

This Briefing is intended for non-EU citizens who wish to invest in Greece, with a minimum capital commitment of €500k. Through such an investment, investors gain two significant benefits:
1.   eligibility for a favorable alternative taxation regime; and
2.   a residence permit in Greece for a minimum period of five years, with the right to travel freely within the European Schengen Area.

In view of the first application of the submission of Top-up Tax Information Returns (GIR Return), and in order to facilitate liable entities that are members of Multinational Enterprise Groups, Decision A.1131/2026 extends the filing deadline for financial years ending on or before 31 March 2025 to 30 October 2026 (initially 30 June 2026).

A draft bill of the Ministry of National Economy and Finance has been submitted to public consultation. The principal provisions concern substantive amendments to the Income Tax Code, Law 4172/2013 (ITC), targeted modifications to the National Customs Code, Law 5222/2025 (NCC), and the establishment of a new tax framework governing the management of alternative investment structures.

On 15 May 2026, the Hellenic Parliament adopted the New Law 5301/2026 (the Law) entitled 'Administrative Cooperation in the Field of Taxation – Transposition of Council Directive (EU) 2023/2226 of 17 October 2023 and Council Directive EU 2025/872 of 14 April 2025 Amending Directive 2011/16/EU on Administrative Cooperation in the Field of Taxation'.

By way of Decision A.1080/2026 (the Decision), the Independent Authority for Public Revenue issued the list of Jurisdictions with which the Multilateral Competent Authority Agreement (MCAA) on the exchange of Country‑by‑Country Reports enters into force and becomes applicable for the 2024 fiscal year, with the exchange year being 2026.

The Ministry of National Economy and Finance has submitted a draft bill for public consultation, entitled 'Administrative Cooperation in the Field of Taxation – Transposition of Council Directive (EU) 2023/2226 of 17 October 2023, and Council Directive EU 2025/872 of 14 April 2025 Amending Directive 2011/16/EU on Administrative Cooperation in the Field of Taxation, and Other Provisions'.

Article 18 of Law 5219/2025 provides an exemption for legal persons and legal entities that hold real rights of full ownership, bare ownership or usufruct over real estate located in Greece from the payment of the Special Real Estate Tax (SRET) of 15% on the value of the property.  

Our Tax Briefing covers recent developments in tax legislation regarding Decision 190/2026 on the Interoperability of Credit Institutions with the Source of Funds Declaration Platform, Decision A.1003/2026 on the National Nomenclature of Economic Activities and Decision A.1004/2026 on the Procedure for Matching Existing Activity Codes (KAD 2008) with the New Activity Codes (KAD 2025).

Our Tax Briefing covers recent developments in tax legislation regarding the 2025 update OECD Model Tax Convention and the Circular E.2110/2025 on the EU Carbon Border Adjustment Mechanism.

Circular E.2094/2025 (the Circular) provides guidelines for the imposition of a Digital Duty on Transactions (DDT) in accordance with the provisions of Law 5177/2025 (the DDT Law).

On 7 November 2025, the Hellenic Parliament adopted the New Law 5246/2025 (the Law) entitled ‘Tax Reform for Demographics and the Middle Class – Support Measures for Society and the Economy’.

Circular E.2088/2025 (the Circular) provides guidelines for the proper application of Articles 47–56, 58 and 59 of Law 5162/2024 (the New Law) on Business Transformations.

A newly introduced draft bill sets out the legislative amendments necessary to implement the announcements made by the Prime Minister during the 89th Thessaloniki International Fair (TIF). 

Decision A. 1126/2025 on Non‐Cooperative Countries for 2024 and Decision A. 1125/2025 on Preferential Tax Regime Countries for 2023.

August's Monthly Tax Briefing covers recent developments in tax legislation, in relation to Circular E. 2055/2025 and Circular E. 2059/2025.

Comprehensive legislation has been introduced in the form of new National Customs Code 5222/2025 (the New Law).