The Global Minimum Tax Initiative: From International Developments to the Greek Framework

The increasing globalization of the economy and the expansion of cross-border activities carried out by multinational enterprises have revealed significant shortcomings in the traditional international tax framework. The ability of multinational groups to allocate profits to low-tax or no-tax jurisdictions, through complex corporate structures and tax planning arrangements, has resulted in substantial erosion of countries’ tax bases and intensified harmful tax competition between jurisdictions. Addressing these challenges became a key priority of international tax policy, leading to the development of the OECD and G20 initiatives aimed at tackling Base Erosion and Profit Shifting (BEPS). In 2013, the OECD and G20 adopted a 15-point Action Plan on BEPS, which resulted in the BEPS package delivered in 2015. The BEPS project sought to address tax avoidance strategies and strengthen the coherence of international tax rules, while ensuring that profits are taxed where the economic activities generating them take place and where value is created. Pillar Two, however, was not part of the original 15 BEPS Actions, but emerged as a subsequent stage in the international tax reform process. Following the work undertaken under the OECD/G20 Inclusive Framework on BEPS, the OECD developed the Global Anti-Base Erosion (GloBE) proposal as part of the broader Two-Pillar Solution to the tax challenges arising from the digitalisation and globalisation of the economy. The Programme of Work published in 2019 marked a significant step towards the development of Pillar Two, which was subsequently further developed and ultimately incorporated into the OECD/G20 international tax reform framework.

The policy objectives underlying Pillar Two extend beyond addressing traditional profit-shifting arrangements. In particular, the framework seeks to address remaining BEPS challenges, establish a floor for excessive tax competition between jurisdictions, and protect developing countries from certain forms of base-eroding payments. In this context, Pillar Two introduces the GloBE Rules, establishing a global minimum effective tax rate of 15% for multinational enterprise groups with consolidated annual revenues exceeding EUR 750 million. The framework is intended to ensure that the profits of large multinational enterprises are subject to a minimum level of taxation, regardless of the jurisdiction in which such profits arise, thereby reducing incentives to shift profits towards more favourable tax environments and limiting the scope for excessive tax competition.The European Union incorporated the principles of Pillar Two through Council Directive (EU) 2022/2523, commonly referred to as the Minimum Taxation Directive, which was adopted in December 2022 with the aim of ensuring the uniform implementation of the GloBE Rules across EU Member States. The Directive forms part of the broader international consensus developed under the auspices of the OECD/G20 Inclusive Framework and seeks to establish a coordinated framework for minimum taxation across participating jurisdictions.

Greece implemented the Directive into its domestic legal order through Law 5100/2024, adopting almost the entirety of the Pillar Two framework and establishing the necessary regulatory and administrative mechanisms for its application. Furthermore, recent developments at OECD level, particularly the publication of the “Side-by-Side” Package in January 2026, introduced additional simplification mechanisms and specific safe harbours aimed at enhancing the practical implementation and stability of the Pillar Two framework.

This article provides an overview of the main provisions of Directive (EU) 2022/2523, examines the fundamental mechanisms underlying the global minimum taxation system, analyzes its implementation within the Greek legal framework through Law 5100/2024, and outlines the most significant developments introduced by the “Side-by-Side” Package regarding the future application of Pillar Two rules.

Basic Terms and Structure of Pillar Two Rules

The Pillar Two framework establishes a global minimum taxation mechanism designed to ensure that large multinational enterprise (MNE) groups that are in scope of the rules are subject to an effective tax rate of at least 15% on the income arising in each jurisdiction where they operate. The primary responsibility for applying these rules lies with the relevant parent entities, including Ultimate Parent Entities (UPEs) and, in certain circumstances, Intermediate Parent Entities (IPEs), particularly where constituent entities of the group are located in jurisdictions with an effective tax rate below the minimum threshold.

The Pillar Two rules generally apply to MNE groups and large-scale domestic groups with consolidated annual revenues of at least EUR 750 million in at least two of the four fiscal years immediately preceding the tested fiscal year. Within an in-scope group, the rules generally apply to its constituent entities, including entities located in jurisdictions where the group has a taxable presence. Certain entities, however, are excluded from the scope of the GloBE Rules by virtue of their nature or status, including governmental entities, international organisations, non-profit organisations, pension funds and certain investment funds. The EUR 750 million revenue threshold therefore constitutes the principal criterion for determining whether a group falls within the scope of the Pillar Two framework, while the specific status and characteristics of individual entities determine whether they are treated as constituent entities or fall within an applicable exclusion.

The determination of whether the minimum taxation level has been achieved is based on the jurisdictional Effective Tax Rate (ETR), calculated by dividing the adjusted covered taxes of the constituent entities located in a jurisdiction by their corresponding qualifying income. For this purpose, adjusted covered taxes comprise current taxes together with certain deferred tax amounts, subject to the adjustments prescribed by the GloBE Rules, while qualifying income (or loss) is based on the financial accounting net income or loss of the constituent entities as adjusted under the relevant GloBE provisions.

Where the jurisdictional ETR falls below 15%, the Directive provides for the imposition of a top-up tax through three complementary charging mechanisms. The primary mechanism is the Income Inclusion Rule (IIR), pursuant to which the parent entity of the MNE group is required to pay the additional tax in respect of low-taxed constituent entities. Where the IIR does not apply, the Undertaxed Profits Rule (UTPR) operates as a secondary mechanism, enabling other jurisdictions in which constituent entities are located to collect the remaining amount of top-up tax. Finally, jurisdictions may introduce a Qualified Domestic Top-Up Tax (QDTT), allowing them to collect the additional tax domestically before the charging rights arise under the IIR or the UTPR.

Beyond the charging mechanisms, the Pillar Two framework also introduces significant compliance obligations. MNE groups remain subject to the OECD Country-by-Country Reporting (CbCR) standards and are required to submit a GloBE Information Return (GIR), containing the information necessary for the calculation of the jurisdictional effective tax rate and any applicable top-up tax, within the deadlines established by the applicable legislation. At EU level, these reporting and information-exchange requirements have been further developed through Council Directive (EU) 2025/872 (DAC9), which establishes the framework for the filing and exchange of the GloBE Information Return among Member States. DAC9 is intended to facilitate the coordinated administration of the Pillar Two rules by enabling the relevant tax authorities to obtain and exchange the information necessary for the assessment and enforcement of the minimum taxation rules.

In Greece, the DAC9 framework has been incorporated into the domestic tax system through the relevant amendments to the Greek tax legislation, complementing the Pillar Two rules already introduced by Law 5100/2024 and establishing the domestic framework for the filing and exchange of the GloBE Information Return.

You can read the full article here: The New Era of Global Minimum Taxation: Pillar Two Rules, Greek Implementation and Key Implications for Businesses – Lexology

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Introduction

Greece has taken a significant step towards modernizing its tax administration with the introduction of a formal Advance Tax Ruling (“ATR”) framework. Enacted through Article 9A of the Code of Tax Procedure by Law 5301/2026, the new regime—effective from 1 October 2026—allows taxpayers to obtain binding guidance from the Independent Authority for Public Revenue (“AADE”) on the tax consequences of contemplated transactions before they are implemented.

Advance tax rulings have long been recognized as an important feature of modern tax administrations across Europe. They provide businesses and investors with greater certainty when undertaking complex transactions, facilitate investment decisions and reduce the likelihood of future tax disputes. By introducing a structured ruling mechanism, Greece aligns itself with the practice followed in many other European jurisdictions and reinforces its broader objective of promoting transparency, predictability and cooperative compliance.

What is an Advance Tax Ruling?

An AΤR is a written interpretation issued by AADE confirming how Greek tax or customs legislation should apply to a specific transaction or arrangement before it is implemented. In this sense, the ATR provides certainty as to how the existing legislative framework should be interpreted and applied to the specific facts presented by the applicant.

The scope of the new framework is deliberately broad. Taxpayers may request rulings in relation to virtually all taxes administered under the Code of Tax Procedure, including corporate income tax, personal income tax, VAT, Digital Transaction Fee and customs matters. This makes the Greek regime one of the most comprehensive advance ruling systems currently available within the European Union.

Who Can Apply and Under What Conditions?

The new framework is designed to resolve genuine interpretative uncertainty before a transaction takes place. Accordingly, an application will generally be admissible only where:

• the transaction or arrangement has not yet been implemented;
• the relevant facts are sufficiently clear and complete to enable a legal assessment; and
• the request raises a genuine “gap” regarding the interpretation or application of Greek tax or customs legislation (meaning an issue that is not addressed by any administrative circulare).

The ruling mechanism is therefore not intended to provide abstract legal opinions or confirm the straightforward application of clear statutory provisions. Instead, it is aimed at situations where uncertainty exists and taxpayers require certainty before proceeding with a proposed transaction.

Article 9A also expressly excludes certain matters from the scope of the regime. Advance tax rulings cannot be requested for:

• transfer pricing matters already covered by the Advance Pricing Agreement (APA) framework;
• issues requiring the interpretation or application of foreign law; or
• matters that are already subject to administrative or judicial dispute resolution involving the applicant.

The Procedure

The ruling process is initiated by submitting an application to AADE together with the prescribed documentation and payment of the applicable administrative fee.

The legislation adopts a variable fee structure, ranging from EUR 3,500 to EUR 50,000, depending on factors such as the complexity of the request, the number of issues involved, the size of the applicant and whether expedited treatment is requested. Where the application is rejected within the statutory deadline, the amount exceeding the initial filing fee is refunded.

Although the level of the fees is higher than in some European jurisdictions, it reflects the highly specialised nature of the ruling process and seeks to ensure that the mechanism is used for transactions involving genuine interpretative uncertainty rather than theoretical or speculative questions.

You can read the full article here: Newsletter_Greece Introduces Advance Tax Rulings A New Era of Tax Certainty

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Law 5313/2026 (Government Gazette A’ 102/25.06.2026) introduces significant amendments to the Greek tax framework applicable to investment funds and investment management activities. The new provisions clarify the tax treatment of foreign investment funds, introduce safe harbors against the creation of Greek tax residence and permanent establishment in specified circumstances, and expand the existing carried interest regime to cover contractual performance-based remuneration.

Tax Treatment of foreign funds

Article 97(1) of Law 5313/2026 amends Article 56 of Law 4706/2020, clarifying the tax treatment of Alternative Investment Funds (AIFs) falling within the scope of Directive 2011/61/EU (AIFMD). The amendment corrects a legislative cross-reference and confirms that foreign EU AIFs remain outside the scope of Greek income taxation.

The legislation further extends the same tax treatment to corresponding collective investment vehicles (hereafter “CIVs”) established outside the European Union, provided that:

• they are not established in jurisdictions included in the EU list of non-cooperative jurisdictions for tax purposes; and
• they are supervised, directly or indirectly through their manager, by a competent authority accredited with the International Organization of Securities Commissions (IOSCO).

According to the explanatory memorandum, the notion of CIVs follows the OECD approach and refers to regulated, widely held investment vehicles holding diversified investment portfolios. As a result, the same tax treatment now applies to qualifying collective investment vehicles established both within and outside the European Union.

Tax Residence and Permanent Establishment

The reform also introduces an important statutory safe harbor designed to facilitate the establishment of investment management functions in Greece.

Firstly, the legislation confirms that the investment activities of qualifying AIFs and CIVs in Greece do not, by themselves, create Greek tax residence or a permanent establishment. This protection extends not only to the investment funds themselves, but also to legal persons and legal entities in which the relevant funds directly or indirectly hold at least 95% of the participation interests and which operate exclusively as holding or investment vehicles (“investment entities”), as well as to fund managers and investors.

Secondly, the legislation provides that the provision of portfolio management, investment management, investment advisory and ancillary services by a Greek management company does not, in itself, create Greek tax residence or a permanent establishment for the relevant investment funds, their investment entities (including sub-funds), fund managers or investors.

These provisions significantly strengthen legal and tax certainty for international fund structures and remove an important source of uncertainty for groups considering the establishment of investment management functions in Greece. This particularly important for hedge funds and other actively managed strategies, where investment decisions are often taken in real time and operational realities do not always align with traditional governance models.

You can read the full newsletter here: Newsletter_Law 53132026 Key Tax Reforms for Foreign Investment Funds, Investment Management Companies and Carried Interest

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Short-term rentals have evolved into one of the most dynamic forms of real estate exploitation, with increasing economic and tax significance. This development has led to the gradual establishment of a stricter legislative framework, which is not limited solely to the tax treatment of rental activity, but also extends to issues of supervision, operational standards, and enforcement mechanisms. Within this context, the legislator seeks to establish clear limits and rules, shaping a more organized and regulated operating environment for the short-term rental market.

The Revised Framework for Short-Term Rentals

The concept of short-term rental is expressly defined in Article 111 of Law 4446/2016, as amended by Article 28 of Law 5073/2023. In particular, according to the above legislative provision, a short-term rental is defined as the lease or sublease of a property, regardless of whether it is listed on a digital platform within the sharing economy or not, and regardless of whether the agreement is concluded through a digital platform, for a specific period of less than sixty (60) days, provided that no services are offered other than accommodation and the provision of bed linens. Based on the literal interpretation of the above provision two key conditions ultimately determine whether a property lease falls within the “law of short-term rentals.” These conditions concern the agreed duration of the lease and the range of services provided by the lessor. Specifically, for a lease to be considered “short-term,” thereby falling under the provisions of the amended Article 111 of Law 4446/2016 and the relevant tax regulations, the agreed duration must be less than sixty days and, in the event that services are provided by the lessor to the lessee, such services must be limited exclusively to the provision of bed linens. For the sake of clarity, it is not required that both the use of the property for a specific period and the provision of bed linen services coexist cumulatively. It is sufficient for the property to be leased for a period of less than 60 days, provided that no other services are offered apart from the aforementioned. No additional conditions are required for a property lease to ultimately fall under this special regime of short-term rentals.

For a better understanding of the new legislative framework governing short-term rentals, it should be noted that prior to the amendment of Article 111 of Law 4446/2016 by Article 28 of Law 5073/2023, short-term rentals were considered exclusively those concluded through a digital platform (e.g., Airbnb, Booking, Vrbo) with a duration of less than one year. Under the current regime, however, a lease does not need to be concluded through an online platform in order to fall under the above special framework, nor does the property need to have been advertised or made available through such platforms.

As previously analyzed, the criteria examined in order to classify a lease as a short-term rental under Article 111 of Law 4446/2016 are: a) the granting of the use of the property by the lessor to the lessee for a period shorter than 60 days, and b) the absence of additional services provided by the lessor to the lessee, apart from the provision of bed linens.

The conclusion of short-term rental agreements through digital platforms within the sharing economy is still permitted under the new legislative framework, subject to the following conditions. The property manager^[1] must be registered in the “Short-Term Accommodation Property Registry” maintained by the Independent Authority for Public Revenue (IAPR), and the registration number in the Registry must mandatorily accompany the property listing in a visible location on digital platforms and in every promotional medium.

You can read the full article on Lexology here: Short-Term Rentals: Stricter Regulatory Framework – New Obligations – Lexology

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Greece

• Shipping companies of Art. 25, L.27/1975, are exempted from both the insurance premium tax and business tax

The No 1028/2017 interpretative Circular issued by the Department of Indirect Taxation (Faculty
A’ VAT) states, inter alia, that they are exempted from premium tax (as established by Art. 29
para. 1, L.3429/2006, as amended and applicable), “the insurance policies concluded by foreign
or domestic shipping companies covered by L.27/1975, are subjective exemptions granted by
Art. 25 and 26 of this law to specific legal persons (private legal entities) and cannot be removed
by a subsequent general provision of law”.
Additionally, by the No 1031/2017 Interpretative Circular issued by the General Department of
the Faculty of the Application of Direct Taxation (Faculty C’-B’) the No. 324/2016 Opinion of the
First Regular Plenary Session of the Legal Council of State was notified, which decided by
majority that the offices or branches of foreign shipping companies settled in Greece under the
provisions of Art. 25 of L. 27/1975, are not subject to the business tax of Art. 31 of L. 3986/2011,
on the grounds that:
“…the provisions of Art. 25 paragraph 3 subparagraph first of L.27/1975, which provide
exemption from any tax, duty, contribution upon the income and are manifestly specific,
with regards to those established tax exemptions for shipping companies under the
regulatory control of the said law, because they are included in the, of major importance
for the general interest, basic special legislative shipping fiscal institutional framework
of the above law … and therefore supersede any subsequent contrary general tax law
provision, and any subsequent tax uniform in the subject to the income tax falls within,
as is the disputed tax under Art. 31 of L.3986/2011…”.

• Guidelines for the application of corporate restructurings under the Greek Income Tax Code

On April 7, 2017 the Head of the Independent Authority of Public Revenues issued the No
1057/2017 Interpretative Circular, which provides the guidelines with respect to corporate
restructurings described in the Greek Income Tax Code. The main elements of the said Circular
are the following:

No 1057/2017 Circular clarifies the conditions for the implementation and the tax
benefits granted within the context of local restructurings (effected between local
entities) and cross-border restructurings (between local and EU entities), provided in
Art. 52-55 of the Greek Income Tax code, namely:

• contribution of assets;
• exchange of shares;
• mergers and demergers;
• transfer of the registered seat of a Societas Europaea to an EU member country.

b) The Ministerial Circular clarifies that the framework for the restructurings referred to in
Art. 52-55 of the Income Tax Code is equally implemented to companies having the
form of a Private Company,
c) It is officially confirmed that for local corporate restructurings the companies can opt in
between the provisions of Income Tax Code and either L.2166/1993 or legislative
decree 1297/1972, and
d) Moreover, it is expressed that for cross-border corporate restructurings, L.2578/1998
is still in force and apply in parallel with the provisions of the Income Tax Code

• The shareholders of a foreign shipowning, managing and chartering company are exempted from the tax on the distribution of dividends
• Recent developments to the tax legislation and to the case law

Romania

Draft Law on prevention

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Greece

Amendments/introduction of new tax provisions

The recently published (on 21.12.2016) law 4446/2016 includes amendments to current tax
provisions and also includes new ones. The most significant of these provisions are the following:

1. Voluntary Disclosure of Income of previous years

A new Voluntary Disclosure Program is introduced for the Undeclared Income of
previous years providing for special conditions and importantly reduced fines. The said
legislation is entered into force on 21.12.2016 and applies to the following taxpayers
(both individuals and legal persons):

a) who have not submitted any tax returns or have submitted incomplete or
inaccurate tax returns for all taxes, duties or contributions and for whom no tax
audit has been issued, and
b) for whom an audit mandate has been already issued or will be issued up to
31.05.2017.

• The above described persons are subject, under certain conditions and deadlines each
  one of them, to additional tax which is further re-adjusted from 5% up to 25%
  depending on the year in which the deadline for the submission of the initial tax return
  expired.
• The application of the Voluntary Disclosure Program ensures that no other
  administrative and/or criminal penalties would be imposed to the taxpayer regarding
  the tax infringements restored by the implementation of the Programme, whilst any
  safeguard measures that have been imposed are relieved.
• The tax due shall be paid in a lump sum within 30 days from the submission of the tax
  return. It is mentioned that the tax would not be refunded, whereas the tax payer may
  benefit form the available debt settlement programs.

1. Safeguard and monitoring of transactions
2. Use of electronic means of payment
3.  Airbnb taxation

• The tax treatment of a foreign legal person
• Procedures for the change of the
  name/address – deregistration of a foreign
  entity
• Tax treatment of the received insurance
  payment following the expiration of a
  group insurance policy
• Automatic Exchange of Financial Account
  Information

Romania

Law no. 209/2016 on the amendment and completion of the Urgency Enactment no. 193/2002 regarding the introduction of modern payment systems

EU

The European Commission proposes a Corporate Tax Package

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Greece

• Withholding tax on the interest obtained from natural and legal persons that do not have their tax residence in the Greece and do not maintain a permanent establishment in Greece
• The Council of State changes the taxation for foreign tax residents, Separate tax declarations for spouses with different tax residence

On 29 June 2016, the Council of State issued the No 1445/2016 decision and clarified the issue of the meaning of art. 4, para. 1 L. 4172/2013 (Income Tax Code) with respect to tax residence of
a natural person in Greece.

Specifically, in order to determine if an individual has a domicile in Greece, all the relevant factors must be taken into account. Especially the existence of household, the physical presence of
him/her, the members of his/her family (which does not include only the spouse and his/her children),the place of performance of its professional activities, the place where its property
interests reside, the place of administrative links to public authorities and institutions (insurance, professional, social), the place of the development of its political, cultural or other activities.
Additionally, under the general social and moral attitudes of this period and depending on the socio-economic data of the spouses, the separate residence of them is possible. Thus, if a
married individual is not obligated to submit income tax return in Greece, on the ground that it is not Greek tax resident, it is not obliged to submit a joint tax declaration with his or her spouse,
solely because the spouse, according to art. 4 para. 1 of the above law meets the criteria to qualify as a Greek tax resident, irrespective whether the obligation to submit a joint declaration is
or is not consistent with precedent force provisions.

Moreover, the electronic system of the tax declarations’ submission does not accept different declarations from spouses, in case one of them is Greek tax resident. However, the said system
should be adapted to the rules of tax law and serve the needs of their correct application and not the opposite.

In conclusion, if an individual does not qualify as Greek tax resident, a double residence issue is not raised. Therefore, there is no need to settle it (residence issue) and remove the conflict of
taxation powers between Greece and the other State, which results the application of the Double Taxation Convention between them

• Alterations to tax provisions

Poland

• Tax on Retail Sale in front of the Polish Parliament

Romania

• L. 112/2016 on the approval of the Urgency Enactment No. 41/2015 for the amendment of certain normative acts, as well as on the provision of certain budgetary measures

EU

• The EU Commission proposal for an EU anti-tax avoidance directive was welcomed by the EU Parliament
• BREXIT: potential tax implications on multinational companies

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Greece

• Changes to Tax Provisions
• Alterations to Income Tax Code
• New online services by the General Secretary of Public Revenues
• Incorporation of Directive 2014/107/EU regarding the mandatory exchange of information in the field of taxation
• Incorporation of Directive 2014/86/EU and 2015/121/EU regarding the conditions for exemption from taxation on intra-group dividends
• The unjustified increase of property can be taxed, even if it appears before 30.9.2010, when law 3888/2010 came into force. The issue was solved by the No 884/2016 substantial preliminary ruling of the Council of State
• Certificate of incomes by dividends, interests and royalties

On the 30th of December 2015, the General Secretary of Public Revenues issued the No
1274/30.12.2015 Circular for the form and the content of the certificate of incomes deriving by
dividends, interests and royalties. Specifically, the persons that are obliged to withholding
taxation for payments, subject to the said tax, made either to natural or legal persons are entitled
to grant to them a single certificate. This certificate includes the total amount of incomes by
dividends, interests and royalties paid within the fiscal year and the tax withheld. The same
obligation exists and to cases where no withholding taxation arises. Moreover, the persons that
are obliged to withholding taxation must submit the single certificate of incomes from distributed
dividends from non-listed in the Stock Exchange market legal persons, interests (except the
interests on deposits), and the royalties via TAXISnet or via magnetic tool to the Tax Authority
regardless of keeping single or double entry books and the way they update them (by the
computerized system or handwritten). For the fiscal year 2015 the said certificate must be
submitted until 31st of December 2016.

Poland

A General Anti-Avoidance Rule towards big tax optimisations

Romania

Government Decree on the approval of the Methodological norms for the application of the New Romanian Fiscal Code

EU

Proposal for Anti-Tax Avoidance Directive

International

Country-by-Country Reporting Standard

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Greece

• Amendments to the Tax Procedure Code (C.T.P.) regarding:
  A. Transfer Pricing penalties
  B. Penalties for the inaccurate filing / non-filing of a tax return
  C. Penalties on V.A.T. infringements
  D. Penalties on infringements regarding withholding taxes

On 17 October 2015, Law 4337/2015 introduced amendments which seek the decrease of the
penalties imposed by the Tax Procedure Code.

A. Transfer Pricing penalties

The penalties imposed for the delayed filing / non-filing / filing of inaccurate Summary Information
Table and for the delayed submission / non-submission of the Transfer Pricing Documentation
File are decreased under the new legislation. Moreover, the said penalties are not calculated on
the legal person’s gross profits, but on the value of the intra-group transactions. Specifically:

• Amendments and new provisions to the Tax Legislation regarding:
  A. The regulation of 100 instalments (‘doses’)
  B. The V.A.T. imposition on educational services
  C. The non-recovered income from the lease of real estate property

• The tax treatment of the capital gain of immovable property

Poland

• The answer on how the new government is going to deliver on election promises

Romania

• Applicable tax to the distributed dividends starting with 1 January 2016

Serbia

• The Serbian parliament has adopted the amendments of the Value Added Tax Law whereas their provisions will be coming into effect successively by 1 January, 2017 while Serbian Ministry of Finance has issued an Opinion regarding the V.A.T. status of return of the unsold merchandise

EU

• V.A.T. – deduction of input value

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Amendments to the Tax Legislation, Significant Amendment to Goods and Services Tax Bill,  a New Fiscal Procedure Code in Romania

Greece

Amendments to the Tax Legislation regarding:

On July 15th 2015, the Law 4334/2015 introduced significant amendments to tax provisions, the most
important of which are described herein
A. Insurance Premiums

The tax rate on all insurance premiums, except from life and fire insurance premiums, is increased from
10% to 15%. Any provision regarding exemptions from the tax on insurance premiums is abolished, except
from life insurance premiums for life contracts over 10 years duration. Specifically,

• in General Liability branch, the premium tax is increased from 10% to 15%
• in car insurance branch, all risks, excluding fire, are raised from 10% to 15%, the fire coverage
  remains at 20% and the civil liability is increased from 10% to 15%
• in fire branch the premium tax remains at 20%
• in health branch, the premium tax of 10% is increased to 15%
• in accident branch the premium tax from 10% is increased to 15%
• in shipping and aircraft branch the premium tax rises to 15%
• in transportable commodity branch the premium tax is raised to 15% from 10% regarding importation
  to Greece and 0% regarding exportations
• in the other branches the premium tax is increased from 10% to 15%

B. Value Added Tax
C. Luxury Taxation
D. Special Solidarity Contribution

Amendments to the tax Legislation with regards to:
A. Income Tax Code
B. Value Added Tax, and
C. Shipping Taxation
D. Regulation of 100 Installments (doses)
E. Debt Collection
F. Control of Financial Statements

Poland

Significant Amendment to Goods and Services Tax Bill New Challenges for Electronic and Petrol Business

Romania

Romania will have a New Fiscal Procedure Code starting from 1 January 2016

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