Greece: Guidance on timing of deductions during balancing market settlement process, tax incentive regime for corporate reorganizations
Circulars 2086/2025 and 2088/2025
The Independent Authority for Public Revenue issued Circular 2086/2025, clarifying that procurement costs incurred by energy suppliers during the balancing market settlement process (pursuant to the balancing market regulation under Decision No. E-245/2024) reduce the gross income of the tax year in which these costs become final, are settled, and the relevant documentation is issued (i.e., the tax year in which the process of their final settlement is completed).
The Independent Authority for Public Revenue also issued Circular 2088/2025, clarifying technical aspects of the tax incentive regime for corporate reorganizations introduced by Law 5162/2024. The guidance covers scope, valuation rules, treatment of gains and losses, cross-border mergers, taxation of investors, and anti-abuse provisions. It confirms alignment with the EU Merger Directive and excludes simultaneous application of earlier incentive regimes.
For more information, contact a KPMG tax professional in Greece:
Antonia Ariel Manika | amanika@cpalaw.gr