On 2 April 2024, the Greek parliament approved a new law that includes provisions for adopting Council Directive (EU) 2022/2523 into Greek legislation. This directive, known as the “EU Pillar Two directive,” is designed to establish a universal minimum taxation standard for multinational and major domestic groups within the EU.
As previously discussed, the law incorporates the implementation of the Pillar 2 income inclusion rule (IIR) and the undertaxed profits rule (UTPR) to establish a minimum tax threshold 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. The legislation additionally includes provisions for implementing a qualified domestic minimum top-up tax (QDMTT), along with specific safe harbors.
The income inclusion rule (IIR) and qualified domestic minimum top-up tax (QDMTT) will be applicable to fiscal years starting on or after 31 December 2023, while the undertaxed profits rule (UTPR) will generally apply to fiscal years starting on or after 31 December 2024.
The law was officially gazetted on 5 April 2024 ( Law No. 5100 published by a third party), and its provisions are generally effective from 1 January 2024.
