Country by Country Reporting (CbCR) Deadlines

November 2018 - Transfer Pricing Alert

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L.4484/2017 harmonizes the Greek and the EU legislative framework regarding the automatic exchange of information in the field of taxation and provides the terms and conditions for the submission of the Country by Country (CbC) Reporting by Multinational Enterprises (MNEs) in Greece.

According to the provisions of L.4484/2017 and Decision issued by Greek Independent Public Revenue Authority (AADE) POL.1184/2017, the CbCreport is applicable to Greek tax resident entities that are members of an MNE group, with a consolidated group turnover exceeding €750 million in the fiscal year preceding the fiscal year to which the CbCreport applies. The deadline for submitting the CbCreport is 12 months after the closing date of the fiscal year to which the CbCreport refers. In this context, for tax year ending on 31st December, the liable legal entities should submit the CbCreport, referring to tax year 2017, no later than 31/12/2018.

In the event of non-filing the required CbCReport, a penalty of €20,000 is imposed, while in case of late or inaccurate submission of a CbCreport, a penalty of €10,000 is imposed. Moreover, Greek tax resident entities forming part of an MNE Group (i.e., Ultimate Parent Entity, Surrogate Parent Entity or Constituent Entity), which are subject to CbCreporting requirements, must notify AADE of the identity and tax residence of the Reporting Entity by sending a special form to the e-mail address Such notification should be submitted no later than the last day of the reporting fiscal year. In this context, for MNE Groups with a reporting fiscal year ending on 31st December 2018, the notification is required to be filed by 31/12/2018.

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