Greece has introduced an omnibus tax bill incorporating DAC8 and DAC9 directives, Pillar Two rules, VAT and penalty reforms, and targeted income tax changes, with staggered effective dates and key administrative measures aimed at strengthening tax transparency and compliance.
Greece introduced an omnibus bill in Parliament on 30 April 2026 through the Ministry of National Economy and Finance, aimed primarily at strengthening tax transparency through the incorporation of EU directives, alongside broad domestic tax reforms and administrative restructuring measures.
The package covers multiple areas, including the non-deductibility of Pillar Two tax, targeted personal income tax changes, VAT and penalty adjustments, and the transposition of amendments to the 2011 Directive on Administrative Cooperation (DAC8 and DAC9).
The main provisions of the bill are as follows:
Implementation of DAC8 and DAC9 (Part A)
The bill transposes Directives (EU) 2023/2226 (DAC8) and (EU) 2025/872 (DAC9) into Greek law by amending Law 4170/2013 on administrative cooperation in taxation.
Under DAC8 (crypto-assets), a mandatory framework is introduced for the automatic exchange of information on crypto-asset transactions and users. Reporting Crypto-Asset Service Providers will collect and submit detailed transaction data to tax authorities. The first reporting period covers the 2026 calendar year. The scope of exchange is also expanded to include non-custodial dividends and advance cross-border rulings for individuals.
Under DAC9 (Pillar Two reporting), the bill introduces a Supplementary Tax Information Return to support the Global Minimum Tax framework. A standardised electronic template will be used, with automatic exchange between EU Member States within three months of filing. The rules apply from the first fiscal year beginning 31 December 2023.
Tax Identification Numbers (AFM) of residents will also be included in automatic exchanges to improve taxpayer identification.
Non-Deductibility of Pillar Two Tax (Part B)
The bill amends Article 23 of the Income Tax Code to clarify that taxes paid under the Global Minimum Tax framework—including the Income Inclusion Rule (IIR), the Undertaxed Profits Rule (UTPR), and any qualified domestic minimum top-up tax—are not deductible business expenses for corporate income tax purposes.
Targeted Personal Income Tax Measures (Part C)
Key personal income tax adjustments include:
- Licensed street market sellers (laiki agora): 50% reduction in minimum annual business income threshold.
- Minors: explicitly exempt from minimum income rules and the business fee (τέλος επιτηδεύματος).
- Skaramagas Shipyards former employees: retroactive wages subject to 20% withholding tax, exhausting further tax liability.
- Housing Coverage Investment Account payments (former Postal Savings Bank employees): treated as income from securities for tax year 2013.
VAT adjustments and penalties (Part C)
- Water utilities (EYDAP, EYATH): technical or operational water losses are not treated as supply of goods and are excluded from VAT self-consumption rules.
- ADMIE services: ancillary services to electricity supply are subject to a reduced 6% VAT rate.
- Late VAT filing penalties: EUR 100 for zero/credit returns; EUR 250 or EUR 500 depending on the accounting system for other late filings. Additional liability of EUR 100 or less attracts a EUR 100 penalty.
- Minors are exempt from late filing penalties for periods of minority.
Administrative and financial measures (Parts D, E & F)
- Binding tax rulings: taxpayers may request advance rulings from the tax authority (AADE) to clarify tax treatment of future transactions.
- Cash payment rule: penalty for businesses accepting cash payments over EUR 500 for consumer sales is doubled.
- ENFIA property tax: from 2027, primary residences in small settlements (under 1,500–1,700 residents depending on region) valued up to EUR 400,000 are exempt.
- Institutional reforms: responsibilities of the Independent Credit Rating Authority are transferred to a new General Secretariat, and an electronic platform is created for non-performing loan (NPL) portfolio transactions.
While the bill generally enters into force upon publication, most provisions in Part A relating to international administrative cooperation will apply from 1 January 2026. Certain measures, such as property tax adjustments and minimum income rules for specific professional categories, have distinct retroactive or future effective dates depending on the provision.
