Greece's AADE has extended the Global Information Return (GIR) filing deadline for multinational enterprise groups with financial years ending on or before 31 March 2025, whilst an accompanying Q&A document clarifies technical filing requirements under Bill 5100/2024.

RF Report

Greece’s tax authority (AADE) published two administrative guidance documents for taxpayers subject to Pillar Two global minimum tax requirements under Bill 5100/2024.

Decision A.1131/2026 establishes the complete filing and information exchange framework for the Top-Up Tax Information Return (GIR), whilst an accompanying Q&A document provides clarification on specific technical and procedural questions arising from GIR implementation.

Together, these instruments offer comprehensive regulatory guidance to support compliance with Greece’s Pillar Two obligations.

Decision A.1131/2026

Greece’s tax authority (AADE) has extended the Global Information Return (GIR) filing deadline to 30 October 2026 for multinational enterprise groups subject to Pillar Two reporting requirements on 29 June 2026.

The extension, formalised through decision A.1131/2026, dated 26 June 2026, applies specifically to obligated entities with financial years concluding on or before 31 March 2025. The postponement was introduced to facilitate compliance during the initial implementation phase of GIR reporting in Greece.

Decision A. 1131/2026 establishes the comprehensive framework for the submission and exchange of the Supplementary Tax Information Return (Global Information Return – GIR) in Greece, directly addressing the Pillar Two reporting requirements.

Persons liable to file 

The obligation to file the GIR falls primarily on constituent entities established in Greece or a designated local entity acting on their behalf. There are specific rules for complex group structures:

  • For joint ventures or minority-owned constituent entities, the return is submitted by the member designated by the Multinational Enterprise (MNE) group or the large-scale domestic group.
  • For multi-parent MNE groups or large-scale domestic groups, the return must be filed by the ultimate parent entities established in Greece or by a single designated filing entity within the country.

The competent AADE unit 

The designated competent authority for receiving and exchanging Global Information Returns (GIRs) is Section E of the Data Services Directorate within the Independent Authority for Public Revenue (AADE), which is responsible for both receiving domestic filings and automatically exchanging them with other EU Member States.

Timing and manner of submission 

Global Information Returns (GIRs) must be submitted electronically to the Liaison Section using the prescribed template and completed in accordance with the OECD’s GloBE guidance. Returns must use the Latin alphabet, and late or non-submission may result in penalties unless a technical failure by the tax administration prevents timely filing, in which case the deadline is automatically extended.

Q&A document

The updated Q&A guidance, dated 18 June 2026, on the implementation of Law 5100/2024 provides specific guidance on notifications relating to the Supplementary Tax Information Return (GloBE Information Return – GIR).

Here are the details concerning the four points:

  • Indicating “NO” in Table 3: A Greek constituent entity must select “NO” in Table 3 of the notification form if Greece will not receive the GIR via automatic exchange of information from the ultimate parent entity’s (UPE) jurisdiction. Furthermore, “NO” must also be selected if the MNE group has designated a different constituent entity to file the return, regardless of whether Greece exchanges information with the UPE’s jurisdiction. Whenever “NO” is indicated, the entity is required to complete Table 4 with the specific details of the designated filing entity.
  • Multi-parented MNE groups: For MNE groups with multiple parent entities, the procedure requires completing Table 3 with the information of the single designated filing entity (in accordance with paragraph 7 of Article 41 of Law 5100/2024). In this scenario, the answer provided in Table 3 must be “YES”.
  • Cyprus’s qualified IIR: The European Commission has clarified via an FAQ that all EU Member States must treat Cyprus as having a qualified income inclusion rule (IIR) in effect. Because of this, if an MNE group files its GIR centrally in Cyprus, its Greek constituent entities are exempt from filing the return locally in Greece.
  • GIR notification obligations: The obligation to submit a GIR notification arises only when domestic constituent entities do not file the GIR locally, but Greece is scheduled to receive it through the exchange of information from another jurisdiction. Conversely, no notification is required if the GIR is filed locally by a domestic ultimate parent entity or a designated filing entity located in Greece. This exemption also applies to constituent entities of a large-scale domestic group.