On 31 July 2020, the Government Officially published Law 4714/2020, which amends the existing advance pricing agreement (APA) provisions. The new Law helps to comply with the minimum standard under Action 14 of the OECD’s base erosion and profit shifting (BEPS) project relating to the rollback rules for APAs. The new provisions applies from 1 January 2014.
The Law declares about the chance of retroactive effect in case of application for bilateral advance pricing agreement or multilateral APA pre-approval. A request for a rollback of the APA may be made in a situation when there are incomplete applications for a bilateral or multilateral APA. Under the Law, the penalty relief for amended returns is subject to the condition that an amended return is submitted by a taxpayer within 30 days of the APA decision notification date. This may also apply if an amended return was filed prior to the new law’s enactment.
