On 30 June 2022, the government of Greece enacted legislation implementing ATAD’s reverse hybrid rule with retroactive effect from 1 January 2022. The rule does not apply to collective investment vehicles.
The new rule applies to situations where one or more associated non-resident companies hold an aggregate direct or indirect interest in 50% or more of the voting rights, equity interests, or rights to share in the profits of a hybrid company when it is incorporated or established in Greece or located in one or more jurisdictions that consider the hybrid entity to be a taxpayer in Greece. This hybrid entity will be considered a Greek tax resident and will be taxed on its income unless such income is otherwise taxed under the laws of Greece or any other jurisdiction.
