Greece: Draft law regarding TP documentation requirements for CbC reporting

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The Parliament of Greece introduced a draft Law 4484/2017 on July 20, 2017 that amends to the Corporate Income Tax Law L.4170 / 2013 and 4474/2017. The suggested amendments contain additional transfer pricing documentation requirements corresponding to the European Union (EU) Guidance 2016/881. In accordance with the draft law, the country-by-country (CbC) reporting will be applicable for business years beginning on or after January 1, 2016.

Greek tax resident entities those are members of a multinational enterprise (MNE) group, with a consolidated group turnover more than Euro 750 mil in the fiscal year previous the fiscal year to which the CbC report applies will have to file the report. The draft law requires that the reporting entity notification is made for domestic subsidiaries and permanent establishments of non-EU MNEs to the Greek tax authorities by December 31, 2017 (for those entities whose fiscal year ended December 31, 2016). The report is required to be provided to the tax authorities within 15 months after the last day of the tax year it refers to. However, the first CbC report will need to be submitted by June 30, 2018 for MNEs with a fiscal year ended on 31 December 2016. Also, CbC report should be prepared in Greek or any other official language of the EU. The report has to cover group revenue, earnings before income tax, income tax paid, Income tax accrued, Shared Capital, Accumulated earnings.

Failure to submit accurate CbC report is sanctioned with monetary penalty (apart from the consequence of the unfavorable risk assessment increasing the probability of a full scope tax audit). The penalty amounts Euro 10,000 is charged in case of non-filing and Euro 5,000 is imposed on late or inaccurate filing.

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