Decision A.1055/2026 for the notification requirement under the Pillar II framework
Τhe Independent Authority for Public Revenue (IAPR) issued οn 12 March 2026, Decision A. 1055/2026 (Government Gazette B’ 1367), which sets out the format and content requirements for notifications to be submitted by Greek constituent entities (“CEs”) under the Pillar II framework.
According to the Decision, Greek constituent entities that are part of Multinational Enterprise (MNE) Groups subject to Pillar II are required to submit a notification to the IAPR. Through such notification, Greek entities must disclose inter alia details regarding the UPE of the MNE Group responsible for filing the GloBE Information Return (“GIR”) in its jurisdiction. If the UPE does not file the GIR, then the Greek CE must report the details of the MNE Group entity designated to undertake this responsibility.
For the first reporting year, the deadline for submitting the notification is set at eighteen (18) months from the end of the first fiscal year for which a GIR filing obligation arises. Accordingly, MNE Groups with a financial year ending on 31 December 2024 are required to submit the notification by 30 June 2026.
As explicitly provided in Decision A. 1055/2026, failure to submit or late submission of the required notification may result to penalties for non-filing or late filing of tax returns, as provided under the provisions of article 53 of the Greek Tax Procedure Code (Law 5104/2024).
In addition, relevant information must be reported in the E3 form for the 2025 tax year by Greek entities belonging to MNE Groups within the scope of Pillar II.
Further guidance from the IAPR is expected regarding the format and content of the GIR and top-up tax return, as well as a Ministerial Decision on the application of transitional safe harbours. The transposition of the DAC9 Directive into Greek law is also anticipated, along with the potential ratification of the OECD Multilateral Competent Authority Agreement (MCAA) for the exchange of GIRs.
Greek entities within the scope of Pillar II should ensure timely preparation for all related filing and notification obligations, particularly due to the fact that the Pillar II rules, as implemented into various countries, have set 30 June 2026 as the relevant deadline.
Given the increased complexity of the new regime and the potential penalties for non-compliance, early planning and coordination will be essential to ensure full and timely adherence to all relevant obligations. The new Administrative Guidance also contains further clarifications regarding Pillar II rules and an updated version of the GIR with relevant guidance regarding its completion.
