AADE has issued a guidance outlining the rules for notifying which entity will submit the Pillar Two Top-Up Tax return. Submissions must be made electronically through myAADE, with deadlines of 15–18 months and penalties for late filings.
Greece’s Independent Authority for Public Revenue (AADE) has issued new guidance, under Decision A. 1055 published on 12 March 2026, for reporting the entity responsible for submitting the Pillar Two Supplementary (Top-up) Tax Information Return.
The decision applies to Greek constituent entities of multinational enterprise (MNE) groups. Each entity must identify which local entity will submit the Top-Up Tax Return and specify the jurisdiction where the reporting entity is established. If a group has multiple Greek entities, only the designated local entity is required to file the notification.
Notifications must be submitted electronically through the myAADE portal, either directly by the entity or via an authorised representative or licensed accountant using Taxisnet credentials. The standard deadline is 15 months after the end of the relevant fiscal year. For the first year an MNE falls under Pillar Two rules, the deadline is extended to 18 months. Notifications do not need to be resubmitted in subsequent years if the information remains unchanged.
Failure to submit on time can trigger penalties under Article 53 of Law 5104/2024. The rules aim to ensure consistent reporting and provide a clear point of contact for Greek authorities regarding Top-Up Tax obligations.
Earlier, the Greek parliament approved a new law that included provisions for adopting EU Pillar Two directive into legislation.
