Tax Updates: February 3rd 2025

The "FASTER" Directive has been adopted

On 10 January 2025, the Directive (EU) 2025/50 on faster and safer relief of excess withholding taxes (FASTER) was published in the Official Journal of the European Union. The Directive will enter into force on 30 January 2025, 20 days after its publication. Member States are required to transpose the Directive into their national legislation by 31 December 2028, with the new rules applying from 1 January 2030.

The key features of the FASTER Directive are that it introduces a common EU digital tax residence certificate, two fast-track procedures complementing the existing withholding tax refund procedure in each Member State, and the establishment of national registers for financial intermediaries that will be able to facilitate the fast-track procedures. For further details on the FASTER Directive, we refer to our relevant newsletter here.

Regulation 2023/1114 ''MiCA'' is now in force

As of 30 December 2024, Regulation (EU) 2023/1114 on markets in crypto-assets (“MiCA”) has entered into full application, which includes regulations to protect cryptocurrency holders, to inform investors about the characteristics and risks of crypto-assets available on the market, to ensure the stability of the financial system and to seize the opportunities for individuals and businesses arising from the upcoming growth of crypto-assets globally.

DAC8: Transposition into national legislation by the end of 2025

The Directive on Administrative Cooperation on tax transparency for crypto-assets (DAC8) provides for the exchange of information between Member States on profits arising from cryptocurrency transactions, which information is required to be reported by cryptocurrency service providers in respect of transactions carried out by customers in the EU. Τhe Directive was adopted in October 2023. Member States will have to transpose it into their national legislation by 31 December 2025 and must apply its provisions as of 1 January 2026 with the first reporting year being 2026.

Tax treatment of cryptocurrency in Greece to be introduced within 2025

According to relevant announcements of the Greek government, it is expected that a specific tax framework for cryptocurrencies as investment products shall be introduced within 2025 in Greece.

Public CbCR: The first public reporting will refer to FY2025

Obligations under Law 5066/2023, which transposed the Directive (EU) 2021/2101 on the public reporting of income tax information by multinational corporations in scope (Public CbC Reporting), apply to financial years beginning after 22 June 2024.
The relevant report shall be published at the General Commercial Registry (GEMI) within twelve (12) months from the end of the financial year for which the report is prepared. Therefore, for enterprises whose financial year coincides with the calendar year, the first public report will relate to FY2025 and shall be published at the General Commercial Registry (GEMI) by the end of 2026.
For further details on public CbCR, we refer to our relevant newsletter here.

CBAM Regulation: 2025 is the last year of the transitional period

Regulation (EU) 2023/956 establishing the Carbon Border Adjustment Mechanism ("CBAM”) entered into force and is already applicable as of 1 October 2023. In Greece, the CBAM provisions were introduced by Circular E.2072/2023. The CBΑΜ is implemented in two phases:

A transitional period (from 1 October 2023 to 31 December 2025) during which, importers are required to report on a quarterly basis a set of data, with no financial burden on embedded emissions. However, penalties may be imposed in the future (for example, for failing to submit the required quarterly CBAM reporting).

A definitive period (starting on 1 January 2026) during which, importers will have to register as licensed CBAM authorized declarants and start buying CBAM certificates, which will generally correspond to the carbon price that would have been paid under EU carbon pricing rules (EU Emissions Trading Scheme) if the goods had been produced within the EU. For further details on CBAM, we refer to our relevant newsletter here.

New OECD guidance on Pillar II and QDMTT

On 15 January 2025, OECD released additional Administrative Guidance with regards to Pillar II rules. In this context, OECD published a transitional central record with jurisdictions having implemented a Qualified Income Inclusion Rule (QIIR), a Qualified Domestic Minimum Top-up Tax (QDMTT) and be eligible for QDMTT Safe Harbour. We note that Greece is included in this record. For further details, we refer to our relevant newsflash here.