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Greece: Law clarifying Pillar Two rules, implementing DAC8 and DAC9 enacted

Effective May 15, 2026

June 3, 2026

The omnibus tax reform, which introduces a wide range of tax measures across corporate taxation, indirect taxes, and transparency rules, was enacted effective May 15, 2026.

Key measures of the reform include:

  • Pillar Two: Clarification that top-up taxes imposed under Pillar Two are non-deductible for corporate income tax purposes
  • DAC8 and DAC9: Implementation of cryptoasset reporting obligations for service providers (DAC8) and a standardized top-up tax information return for Pillar Two purposes, with exchanges between EU member states (DAC9).
  • Advance tax rulings: Introduction of formal advance tax rulings regime, allowing taxpayers to obtain binding guidance from the tax authorities on the tax treatment of planned transactions

Read a June 2026 report prepared by KPMG’s EU Tax Centre

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