It was tabled in Parliament the draft law of the Ministry of National Economy and Finance regarding the incorporation into national law of the European Directive 2022/2523/EU (Pillar II) and provides for the establishment of a minimum tax rate for multinational companies and large-scale national groups, which can lead to an additional tax of up to 15%.

The bill also includes provisions that enable the Minister of National Economy and Finance to suspend for up to 12 months the collection of overdue debts to the State of citizens affected by natural disasters as well as provisions on tax and customs issues and on the status operation of the State Real Estate Company.

With the incorporation of the Directive, which is compulsorily applied from 1/1/2024 by the member states, Greece harmonizes with the rest of the EU countries. and the related OECD initiative which has been adopted by 132 countries. This is an important step in tackling tax avoidance and ‘competition to the bottom’, that is, the exploitation, particularly by multinational groups, of different taxation from state to state in order to pay less tax.

What changes does the bill bring?

The new system applies a global minimum level of taxation with an effective tax rate of 15% for multinational business groups and large-scale domestic groups with an annual turnover of more than €750 million for at least 2 of the last 4 years before 2024. This system may lead to an additional additional tax of up to 15% on profits, if these businesses paid less than this in taxes.
It is noted that, with data from 2022, in Greece there are 19 Greek business groups and 900-950 subsidiaries of foreign groups that belong to the above categories. It is estimated that the additional tax revenues that will be collected will amount to up to 80 million euros.
It is clarified that the tax rate for companies remains at 22% and will continue to be affected by a number of other parameters (tax incentives, loss carryovers, etc.), which lead to its fluctuation.

Supplementary provisions

The draft law provides for a provision so that the Minister of National Economy and Finance can now, by his decision, suspend for up to 12 months the collection of overdue debts to the State of citizens who have been affected by natural disasters.
In addition, some additional provisions have been included to optimize customs and tax controls, such as the possibility of using a digitized handwritten signature when carrying out controls, the management (storage, sale, processing or disposal) of confiscated products by the customs authorities, as well as the development of interoperability for the mandatory electronic issuance and sending of administrative documents of the AADE.
Finally, a provision is included that provides for the harmonization of the operating and hiring regime governing the Public Real Estate Company (ET.A.D.) with that governing the other direct subsidiaries of the Hellenic Holdings and Property Company (E.E.S.Y. PI.).