Greece has transposed the DAC 9 provisions of Council Directive (EU) 2025/872 into domestic law through Law 5301/2026, published in the Greek Official Gazette on 15 May 2026. The law updates the automatic exchange of information rules on advance tax rulings, crypto-asset reporting and OECD Pillar Two reporting obligations. DAC 9 was required to be transposed by 31 December 2025, but Greece missed the deadline, prompting the European Commission to open an infringement case; that issue was resolved with the enactment of the new law.
AC 9 introduces a centralised compliance mechanism for multinational enterprise (MNE) groups, allowing a single top-up tax return under the global minimum tax rules to be filed at the group level. It also establishes a standardised reporting template aligned with the OECD GloBE Administration and Compliance model and expands the automatic exchange of information among EU member states to include the top-up tax return.
A key component of the Greek law is the adoption of a standardised GloBE Information Return (GIR), consistent with the OECD template, to support the automatic exchange of GIRs across the EU. The legislation introduces significant changes for filing and exchanging GIRs under the Pillar Two framework, most notably the implementation of a common GIR format to facilitate uniform reporting and cross-border cooperation. Under the law, Greek constituent entities (CEs) are not required to file a GIR with the Greek authorities if a GIR has already been filed in another EU member state by the ultimate parent entity or a designated filing entity. Instead, CEs must notify the Greek tax administration of the relevant filing (in accordance with Ministerial Decision A.1155/2026).
GIRs must be exchanged between competent authorities of each EU member state within three months of the GIR due date for each member state, using the standardised electronic format established by Implementing Regulation 2025/1325. For the first reporting year, Law 5301/2026 provides that the exchange of GIRs will take place no later than six months after expiry of the filing deadline, and in any event, no earlier than 1 December 2026.
Consistent with DAC 9 and the OECD dissemination model, the law establishes a tiered sharing approach: the General Section of the GIR is shared with member states where the MNE group’s CEs are located, while jurisdiction-specific sections are shared only with member states that have taxing rights under the Pillar Two rules with respect to the relevant jurisdictions. The law also outlines procedures for addressing inconsistencies identified during the exchange process. Greece’s tax administration must notify another member state if a GIR is erroneous, incomplete or missing after prior notice that a GIR would be filed in that jurisdiction. Additional guidance from the tax administration is expected.
Importantly, the legislation confirms that the Pillar Two top-up tax is a nondeductible expense for Greek corporate income tax purposes.
Theodoros Kindis
Dr. Yiota Radovits
BDO Greece
AC 9 introduces a centralised compliance mechanism for multinational enterprise (MNE) groups, allowing a single top-up tax return under the global minimum tax rules to be filed at the group level. It also establishes a standardised reporting template aligned with the OECD GloBE Administration and Compliance model and expands the automatic exchange of information among EU member states to include the top-up tax return.
A key component of the Greek law is the adoption of a standardised GloBE Information Return (GIR), consistent with the OECD template, to support the automatic exchange of GIRs across the EU. The legislation introduces significant changes for filing and exchanging GIRs under the Pillar Two framework, most notably the implementation of a common GIR format to facilitate uniform reporting and cross-border cooperation. Under the law, Greek constituent entities (CEs) are not required to file a GIR with the Greek authorities if a GIR has already been filed in another EU member state by the ultimate parent entity or a designated filing entity. Instead, CEs must notify the Greek tax administration of the relevant filing (in accordance with Ministerial Decision A.1155/2026).
GIRs must be exchanged between competent authorities of each EU member state within three months of the GIR due date for each member state, using the standardised electronic format established by Implementing Regulation 2025/1325. For the first reporting year, Law 5301/2026 provides that the exchange of GIRs will take place no later than six months after expiry of the filing deadline, and in any event, no earlier than 1 December 2026.
Consistent with DAC 9 and the OECD dissemination model, the law establishes a tiered sharing approach: the General Section of the GIR is shared with member states where the MNE group’s CEs are located, while jurisdiction-specific sections are shared only with member states that have taxing rights under the Pillar Two rules with respect to the relevant jurisdictions. The law also outlines procedures for addressing inconsistencies identified during the exchange process. Greece’s tax administration must notify another member state if a GIR is erroneous, incomplete or missing after prior notice that a GIR would be filed in that jurisdiction. Additional guidance from the tax administration is expected.
Importantly, the legislation confirms that the Pillar Two top-up tax is a nondeductible expense for Greek corporate income tax purposes.
Key takeaways
- Centralised filing mechanism: DAC 9 enables a single top-up tax return to be filed at the group level, reducing administrative burdens for MNE groups.
- Alignment with OECD standards: The standardised GIR format mirrors the OECD/G20 Inclusive Framework template.
- Enhanced transparency and cooperation: Automatic exchange of GIRs is strengthened, with strict timelines for member states.
- Limited local obligations: Greek entities may rely on filings made in other EU jurisdictions, subject to a notification requirement.
- Tax impact: The nondeductibility of the Pillar Two top-up tax may affect effective tax rate calculations and financial reporting.
Theodoros Kindis
Dr. Yiota Radovits
BDO Greece