Greece: Guidance on requirements for constituent entity notifications under Pillar Two rules

Decision A.1055/2026 issued March 12, 2026

The Independent Authority for Public Revenue (IAPR) on March 12, 2026, issued Decision A. 1055/2026, setting out the format and content requirements for notifications to be submitted by Greek constituent entities (CEs) under the Pillar Two rules.

The deadline for submitting the notification for the first reporting year is 18 months from the end of the first fiscal year for which a GloBE information return (GIR) filing obligation arises. Accordingly, multinational enterprise (MNE) groups with a financial year ending December 31, 2024, are required to submit the notification by June 30, 2026. 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 Two.

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 harbors. 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.

Read a March 2026 report prepared by the KPMG member firm in Greece

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Greece: Guidance on requirements for constituent entity notifications under Pillar Two rules

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