Greek tax administration issues Circular POL 1184/2017 on procedural aspects of filing and exchange of Country-by-Country Reports. Zepos & Yannopoulos, Taxand Greece presents an overview.
Pursuant to the transposition of Council Directive (EU) 2016/881 introducing the automatic exchange of Country-by-Country (CbC) reports within the EU and the ratification by Greece of the “Multilateral Competent Authority Agreement on the Exchange of CbC Reports” under Law 4490/2017, Greek tax authorities have issued Circular POL 1184/2017 in order to determine the main aspects with regards to the procedure of filing and exchange of CbC Reports.
By way of reminder, CbC reporting obligations apply for MNE groups with an annual consolidated turnover exceeding the amount of Euro 750M.
The issued guidelines stipulate a range of procedural issues, such as the competent directorate in the Ministry for receiving and exchanging CbC reports, the electronic platforms and methods for communicating said files to the administration, the language of the Report etc., while explicitly referring to the OECD Transfer Pricing Guidelines in relation to the implementation of the CbC reporting obligation.
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Until 6 December 2017, Greece has committed to exchange CbC Reports with all EU member states and 41 other OECD member states as of mid-2018. As regards exchange of CbC reports with the US in particular, ratification of the bilateral Competent Authority Arrangement between the US and Greece, signed on 27 September 2017, is currently pending.
