On 28 July 2017, Law 4484/2017 was adopted, according to which Greek Legislation is adapted to the provisions of Directive (EU) 2016/881.
The Country by Country Report applies to legal entities resident in Greece, who are members of a multinational enterprise group, with a total consolidated income of more than € 750 million in the tax year preceding the tax year to which the Country by Country Report refers.
The purpose of the Report is to provide the opportunity to assess significant risks in relation to intra-group pricing and other risks related to tax base erosion and profit transfer.
If the ultimate parent entity of the group is a tax resident of Greece and subject to the Country by Country Report, this entity is liable to submit the said Report to the tax authorities within 12 months of the last day of the tax year to which it refers.
An entity that is a tax resident of Greece and is not a final parent of the group will be required to submit the Country by Country Report in Greece if one of the following situations occurs:
• The country where the ultimate parent is tax resident does not have the obligation to submit a Country Report.
• The country of which the ultimate parent is tax resident has not entered into the current Special Agreement of Authorities, with which requires the automatic exchange of Country by Country Report with Greece.
• The country of which the ultimate parent is tax resident has been systematically unable to comply with the submission of the Country by Country Report.
However, it should be noted that the entity of group which has its tax residence in Greece, is required to inform the competent Greek tax authorities about the entity of group which is responsible for submission of Country by Country Report, until the last day of the tax year mentioned in the Country by Country Report. For the first year of application, the deadline is extended to the last day of submission of the Country by Country Report.
The late or non-submission of the Country by Country Report is sanctioned. The fine imposed for non-submission of the Country by Country Report amounts to € 20,000, whereas in case of late submission or submission of inaccurate information the fine is € 10,000.
Volakaki Katerina Assistant Analog Group
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