Greece's tax authorities have moved decisively to close reporting gaps that have long affected foreign entities with economic activity in the country. Effective from the 2025 fiscal year – with first compliance obligations falling due in early 2026 – Greece has introduced reinforced reporting rules under its tax legislation. These changes apply specifically to non-resident companies, foreign branches, and cross-border structures that generate Greek-source income or maintain a presence on Greek territory. For international businesses that have operated under legacy arrangements, the window to adapt is narrowing.
Greece's updated tax reporting rules require foreign entities earning Greek-source income or constituting a permanent establishment on Greek territory to file enhanced disclosures with the Anexartiti Archi Dimosion Esodwn (Independent Authority for Public Revenue, IAPR). The primary compliance deadline for the 2025 fiscal year falls in the first quarter of 2026. Entities that fail to file – or file incomplete disclosures – face financial penalties under Greek tax legislation and risk reclassification of their tax residency status.
This alert summarises what has changed, which business categories are in scope, and the immediate steps international companies should take before the deadline.
What has changed and when it takes effect
Greek tax legislation has been amended to impose broader disclosure obligations on foreign entities. The changes address three distinct areas.
First, the definition of mónimis egkatástasis (permanent establishment) has been expanded. Activities previously considered preparatory or auxiliary – including certain digital services, warehousing arrangements, and dependent agent relationships – may now constitute a taxable presence in Greece. Entities that previously concluded they had no Greek permanent establishment should reassess that position.
Second, enhanced reporting applies to corporate income tax and withholding tax obligations. Foreign companies receiving dividends, royalties, interest, or service fees from Greek-resident payors must now confirm their tax residency status and the applicability of any tax treaty benefit through updated documentation submitted to the IAPR. Payors that apply reduced withholding tax rates without receiving the required documentation from their foreign counterparties bear primary liability for any shortfall.
Third, controlled foreign company rules have been updated to require Greek-resident parent entities to disclose interests in foreign subsidiaries meeting certain income and substance thresholds. This aspect of the reform affects outbound structures as well as inbound ones.
The effective date for all three changes is the 2025 fiscal year. Reporting obligations arising from these changes are due within the standard tax return filing windows of 2026, which close by the end of the first quarter for most entity types.
Which foreign entities are affected – and the threshold criteria
The new reporting requirements apply broadly, but their practical impact concentrates on four categories of foreign entity.
Foreign companies with a Greek permanent establishment. Any non-resident entity that. following the expanded definition. now qualifies as having a permanent establishment in Greece must register with the IAPR. File a Greek corporate income tax return. Additionally, disclose all Greek-source revenue attributable to that establishment. The registration obligation arises as soon as the permanent establishment conditions are met – not at the point of first filing.
Recipients of Greek-source passive income. Non-resident entities receiving dividends, interest, royalties, or technical service fees from Greek payors must provide current tax residency certificates and, where applicable, treaty entitlement documentation. Entities relying on a tax treaty to secure a reduced withholding tax rate face the most immediate exposure: without updated certification, payors are obligated to apply the standard domestic withholding rate.
Foreign entities participating in Greek partnerships or joint ventures. Pass-through structures with a Greek element. including joint ventures, real estate co-investment vehicles. Additionally. Economic interest groupings. now require each foreign participant to file an individual disclosure confirming its tax position with respect to Greek-source income.
Greek-resident entities with foreign subsidiaries. Parent companies incorporated in Greece that hold interests in foreign subsidiaries must disclose those interests where the subsidiary meets the income composition and low-taxation thresholds set out in the controlled foreign company provisions of Greek tax legislation.
Entities below de minimis income thresholds may qualify for simplified reporting, but the thresholds are set at levels that capture a wide range of active commercial relationships. Entities should not assume de minimis treatment without a specific assessment.
For tailored advice on how these changes affect your structure in Greece, contact us at info@ferrazwhitmore.com or visit our Greek tax law practice page.
Immediate action items for international companies
International businesses with any Greek exposure should treat the following five steps as priorities before the 2026 filing windows open.
- Reassess permanent establishment status. Apply the updated definition to existing Greek activities. Warehouse operations, digital service delivery through Greek servers, and arrangements with Greek agents or distributors all warrant fresh analysis. If a permanent establishment now exists, registration with the IAPR must occur promptly – delay does not suspend the obligation or the associated penalties.
- Audit withholding tax arrangements. Review all payments flowing from Greek-resident payors to your entity. Confirm that current tax residency certificates are in place and that any tax treaty position is properly documented. Certificates older than one year are frequently rejected by the IAPR under updated procedural rules.
- Update intra-group documentation. Where Greek subsidiaries or branches make payments to foreign group members – including management fees, royalties, and intercompany loans – verify that transfer pricing documentation meets current Greek requirements. The reporting changes have increased scrutiny of intra-group flows that previously attracted limited audit attention.
- Review controlled foreign company exposure. If your group includes a Greek-resident holding or operating company, assess whether foreign subsidiaries now fall within the updated controlled foreign company provisions. Early disclosure is preferable to a corrective filing made after an IAPR query.
- Map compliance deadlines by entity type. The first-quarter 2026 deadline is a general reference point. Specific filing dates vary by entity type, income category, and whether the entity has elected a non-standard fiscal year. Construct a compliance calendar now rather than relying on a single deadline assumption.
Companies that identify reporting gaps should consider voluntary disclosure before the IAPR opens compliance reviews. Greek tax legislation provides a more favourable penalty regime for self-initiated corrections than for deficiencies discovered during audit. The cost of proactive compliance is consistently lower than the combined financial and reputational cost of a contested assessment.
For companies navigating related corporate law obligations that arise alongside these tax changes, our corporate law practice in Greece addresses registration, branch structuring, and entity governance requirements in parallel.
International companies comparing their Greek exposure to obligations in other EU jurisdictions may also find our alert on 2025 tax reporting changes in Portugal a useful reference for understanding how southern European regulatory patterns are converging.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising business clients across 46 jurisdictions. Our tax law practice supports international companies, institutional investors, and in-house legal teams on corporate income tax compliance, withholding tax structuring, tax treaty applications, and permanent establishment risk across European and Atlantic jurisdictions. Engaging a lawyer in Greece with cross-border experience is essential when new reporting obligations intersect with complex group structures. and as a law firm in Greece and across the EU. We provide coordinated advice that covers both local compliance and cross-border strategy. Our team combines Portuguese civil law expertise with English common law tradition to deliver results-oriented counsel across multiple legal systems. To discuss how Greece's updated tax reporting requirements apply to your entity, contact us at info@ferrazwhitmore.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.