On 7 March 2024, the Greek government presented a draft law to Parliament after a public consultation period. This law implements the European Union’s Minimum Taxation Directive (2022/2523) of 14 December 2022.
As previously discussed, the law incorporates the implementation of the Pillar 2 income inclusion rule (IIR) and the undertaxed payment/profit rule (UTPR) to guarantee a minimum tax rate of 15% for multinational enterprise (MNE) groups with annual consolidated revenue of at least EUR 750 million in at least two of the preceding four fiscal years.
Additionally, the law includes the introduction of a qualified domestic minimum top-up tax (QDMTT), along with specific safe harbors. Pending approval and publication in the Official Gazette, the IIR and QDMTT will be effective for fiscal years starting on or after 31 December 2023, while the UTPR will typically be applicable for fiscal years starting on or after 31 December 2024.
