This decree ensures both the legal enforcement of Greece’s Pillar Two provisions and the transparent availability of official state publications for public access.
Greece’s Ministry of Finance (MoF) has confirmed that the undertaxed profits rule (UTPR) and the transitional country-by-country reporting (CbCR) safe harbours under Pillar Two, as established in the Minimum Taxation Directive (2022/2523), officially took effect from 5 April 2024, the date of publication of the relevant Greek legislation.
The confirmation comes through an official document published in the Government Gazette of the Hellenic Republic on 23 March 2026 (Issue B, No. 1616). This ministerial decree, issued by the Ministry of National Economy and Finance, formally activates Articles 34 and 35 of Law 5100/2024. It cites existing legislative frameworks and presidential decrees to provide the necessary legal authority for this implementation.
This decree ensures both the legal enforcement of Greece’s Pillar Two provisions and the transparent availability of official state publications for public access.
Earlier, Greece’s Independent Authority for Public Revenue (AADE) issued 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.
