AADE has made an online application available for filing constituent entities' top-up tax returns under Law 5100/2024 (Pillar Two). Groups with a reference fiscal year ending on or before 31 March 2025 must file by 30 November 2026.
Greece’s Independent Authority for Public Revenue (AADE) announced that the myAADE application has been made available from 2 November 2026. Taxpayers can use it to submit top-up tax returns of constituent entities under Law 5100/2024 (Pillar Two).
The filing and payment procedures are set out in decisions A.1236/2026 and A.1237/2026 of Aade Governor Giorgos Pitsilis.
Types of return
The application covers two types of return:
- Constituent Entities’ Top-up Tax Return, filed under the Income Inclusion Rule and the Undertaxed Profits Rule.
- Domestic Top-up Tax Return of Constituent Entities, filed under Article 12 of Law 5100/2024.
Who must file
For the Constituent Entities’ Top-up Tax Return, the filer depends on the rule applied:
- Income Inclusion Rule: the ultimate parent constituent entity or the designated constituent entity, provided it is established in Greece.
- Undertaxed Profits Rule: the domestic constituent entity or the designated local entity.
The Domestic Top-up Tax Return must be filed by the Greek-established constituent entity of a multinational enterprise group or of a large-scale domestic group.
Deadlines
Multinational enterprise groups and large-scale domestic groups whose reference fiscal year ends on or before 31 March 2025 have two deadlines:
- Submission of returns: by 30 November 2026.
- Payment of the tax: by 31 December 2026.
How to file
Returns are submitted through the myAADE digital portal (myaade.gov.gr), by selecting Applications – Tax Services – Income – Top-up Tax, Law 5100/2024 (Pillar Two).
