IAPR issued Circular E.2088/2025 on 10 October 2025, detailing rules for the new corporate reorganisation tax incentives.
Greece’s Independent Authority for Public Revenue (IAPR) has released a Circular E.2088/2025 on 10 October 2025, outlining key technical details of the new tax incentive framework for corporate reorganisations.
The circular explains the regime’s scope, relevant definitions, and rules for valuing assets and securities. It outlines the tax treatment of gains from reorganisations, as well as the handling of losses, reserves, and provisions. It also covers cross-border mergers, divisions, and conversions involving European companies (SE) and European cooperative societies (SCE), including the taxation of Greek shareholders or partners in transparent entities.
It addresses anti-abuse measures, transitional rules, and repeals, ensuring consistent application of the tax incentives. It details domestic and cross-border transformations, covering asset and share valuation, taxation of resulting goodwill, carryover of depreciation and losses, and special rules for contributions from sole proprietorships or joint ventures.
The circular confirms that the new law modernises and unifies previous tax incentives, promoting tax neutrality throughout corporate transformations.
