Greece has enacted Law No. 5301/2026, introducing DAC8 and DAC9 reporting rules, confirming the non-deductibility of Pillar Two top-up taxes, and revising VAT, tax ruling, and shipping tax provisions.
Greece has enacted Law No. 5301/2026, introducing new crypto-asset reporting rules, Pillar Two tax measures, VAT amendments, and changes to shipping taxation after the legislation was published in the Official Gazette on 15 May 2026.
The law implements Council Directive (EU) 2023/2226 (DAC8) and Council Directive (EU) 2025/872 (DAC9), creating new reporting and due diligence obligations for crypto-asset service providers and establishing procedures for the filing and exchange of Top-up tax (GloBE) information returns under the European Union Minimum Taxation Directive (2022/2523).
The legislation also confirms that supplementary (top-up) tax under the Pillar Two Income Inclusion Rule (IIR), Under-Taxed Profits Rule (UTPR), and the Qualified Domestic Minimum Top-up Tax (QDMTT) will be treated as a non-deductible business expense for corporate tax purposes.
Other measures include a reverse charge mechanism for construction services, a reduced 6% VAT rate for electricity transmission and rebates, and reductions in certain tax penalties.
The law further introduces a framework for binding tax rulings issued by the Greek Public Revenue Authority (AADE). Applications may be submitted by natural persons, legal entities, and legal arrangements, with fees ranging from EUR 10,000 to EUR 50,000 and a minimum application fee of EUR 3,500. It also establishes mandatory automatic exchange of information between EU member states regarding advance cross-border rulings.
Amendments to the tonnage tax regime include annual increases between 2026 and 2030 for first-category ships and related Naval Retirement Fund contributions, alongside reductions and exemptions for certain second-category ships based on factors such as use, age, and maintenance.
The DAC8, DAC9, and ruling exchange provisions will apply from 1 January 2026, while the binding ruling framework will take effect on 1 October 2026. Most remaining measures entered into force on 15 May 2026.
Earlier, 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.
