Public Consultation on draft legislation for DAC9 Implementation in Greece
On 27 March 2026, the Greek Ministry of Finance initiated a public consultation on a draft bill providing inter alia the implementation of the Council Directive (EU) 2025/872 (DAC9) into Greek law.
In this regard, the draft legislation introduces a standardized format for the GloBE Information Return (GIR), aligned with the template developed by the OECD, so that such returns are automatically exchanged between EU Member States.
To this end, a Greek constituent entity (CE) will not be required to file a GIR with the Greek tax authorities if such return has already been submitted in another EU Member State by the ultimate parent entity or a designated filing entity of the group. Under these circumstances, the only obligation towards the Greek tax authorities will be the filing of a GIR notification, as per the explicit provisions of the Ministerial Decision A.1155/2026.
According to the provisions of the draft bill, the GIR should be exchanged with the competent EU Member States no later than three (3) months after the filing deadline for the reporting fiscal year, through the utilization of a standardized electronic format, as stipulated in Implementing Regulation 2025/1325. In this regard, we remind you that the Greek Pillar II legislation provides that for the transitional year, the GIR needs to be filed within eighteen (18) months after the end of the reporting fiscal year.
The exchange of the relevant sections of the GIR will be implemented in accordance with the dissemination approach approved by the OECD and provided under DAC9. In this context, the respective sections of the GIR will be disclosed to the EU Member States in line with their taxing rights under the Pillar II rules.
Moreover, notification procedures will be implemented to address any discrepancies or issues identified in the exchange of GIRs between EU Member States. In particular, the Greek tax authorities will be required to notify the relevant EU Member State if a GIR is received with errors or omissions, or if no such return has been received despite prior notification of a Greek CE that such return (GIR) will be filed to the respective EU Member State. Further clarifications and detailed guidance on such procedures are expected to be set out in Decisions to be issued by the Independent Authority for Public Revenue (IAPR).
In addition, a very important issue to point out is that in accordance with the provisions of the draft law, Pillar II top-up tax is added to the list of non-deductible expenses explicitly stipulated in the Greek Income Tax Code.
