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Greece: Guidance on taxation of distribution or capitalization of untaxed profits from prior years

Circular 2096/2025

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January 5, 2026

The Independent Authority of Public Revenue (AADE) issued Circular 2096/2025 clarifying that profits from prior years of legal entities referred to in Article 45(a) of the Income Tax Code (i.e., capital companies) are not subject to tax upon their distribution or capitalization, provided they relate to periods when the legal entities were exempt from income tax.

The circular specifically refers to legal entities that, due to privatization (e.g., transfer of shares by the Hellenic Republic Asset Development Fund or HRADF), are no longer considered exempt entities under Article 46 of the Income Tax Code and proceed with the distribution or capitalization of profits originating from exemption periods.


For more information, contact a KPMG tax professional in Greece:

Ariel Manika | amanika@kpmg.com

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