Greece has introduced a draft law on 30 April 2026 setting out broad tax transparency reforms, including DAC8 and Pillar Two implementation, alongside a new advance tax ruling framework and institutional restructuring measures.
Greece has unveiled a draft law on 30 April 2026 introducing wide-ranging tax transparency reforms, institutional restructuring measures and a new advance tax ruling framework, alongside the transposition of key EU tax directives including DAC8 and the Pillar Two global minimum tax regime.
The legislation incorporates Directive (EU) 2023/2226 (DAC8), expanding automatic exchange of information to crypto-assets, dividend data outside custody and advance cross-border rulings for individuals. Crypto-Asset Service Providers will be required to collect and report detailed transaction data, including gross amounts and units for acquisitions and disposals, with the first reporting cycle covering the 2026 calendar year.
It also transposes Directive (EU) 2025/872 on the Pillar Two global minimum tax, establishing a framework for automatic exchange of information related to the Supplementary Tax Information Return. Multinational enterprises must use a standardised reporting template for these obligations.
Institutional reforms include the abolition of the Independent Credit Rating Authority, with its functions transferred to the General Secretariat of the Financial Sector and Private Debt Management, which will operate an integrated system for assessing creditworthiness of individuals and legal entities. The law also establishes an Electronic Platform for Transactions of Non-Performing Loans (NPLs) to facilitate portfolio trading between investors, banks and credit management companies.
The Hellenic Corporation of Assets and Participations (HCAP/EESYP) is assigned enhanced asset utilisation responsibilities, with a 1% fee on proceeds allocated to cover administrative and operating costs.
A new Binding Tax Ruling (PDA) mechanism is introduced under the Independent Authority for Public Revenue (AADE), allowing taxpayers to obtain advance legal interpretations of tax legislation for specific future transactions upon payment of a fee. These rulings are binding on the tax administration but not on taxpayers, and are subject to a 150-day processing period. Fee levels are structured according to complexity, number of issues, applicant size and legal form, and whether expedited processing is requested, with minimum and total ranges set via ministerial decision between EUR 5,000 and EUR 15,000–EUR 50,000.
Separately, an advance tax ruling (ATR) mechanism is introduced, providing binding interpretations for defined future facts under tax and customs law. ATRs remain binding on the administration provided conditions are unchanged and no conflicting supreme court ruling exists. The regime excludes transfer pricing advance pricing arrangements, foreign law matters and cases under dispute. ATRs will be published in anonymised or pseudonymised form on the AADE website, subject to protection of commercially sensitive information.
The draft law also introduces property tax exemptions from 2027 for primary residences in settlements with fewer than 1,500 residents (or 1,700 in border areas), subject to a EUR 400,000 property value cap. Additional measures include penalties equal to double the value of cash payments exceeding EUR 500, tax relief for minors including exemption from business activity tax for 2023–2024 income, and the removal of penalties for late filing by minors.
Sectoral provisions include a 4% annual increase in ship contribution rates from 2026 to 2030, recruitment flexibility for EYDAP and EYATH water utilities subject to regulatory approval, VAT clarification for technical water losses, and permission for the Hellenic Aerospace Industry (EAB) to employ retired military personnel on fixed-term contracts exempt from pension reduction rules. A new system for anonymised higher education data collection is also established for policy planning.
The draft law enters into force upon publication, with DAC8 and crypto-asset reporting provisions applying from 1 January 2026, while selected tax relief measures, including property tax exemptions, are phased in from 2027.
