Greece: Country-by-country reporting update | KPMG | US

Greece: Country-by-country reporting update

Greece: Country-by-country reporting update

A new law approved in early October 2017 reflects ratification by Greece of the multilateral competent authority agreement on the exchange of country-by-country (CbC) reports.

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With this action, certain CbC reporting rules will apply to multinational enterprises (MNEs) with operations in Greece, including:

  • Requirements for filing CbC reports by the ultimate parent entity of an MNE group that is a resident for tax purposes in Greece
  • An exemption for MNE groups with total consolidated group revenue less than €750 million for the immediately preceding fiscal year
  • Due dates for filing the CbC report (in general, within 12 months from the last day of the “reporting” fiscal year to which the CbC report relates, with the first filing due by 31 December 2017 for 2016)
  • Notification to be made to the Greek tax authorities by MNE group members for the filing of the CbC report

KPMG observation

The CbC report, together with the Master file and Local file, represents a standardized approach to transfer pricing documentation, and will provide the tax authorities with information that would allow for efficient transfer pricing risk analysis. Information contained in the CbC report is expected to be used in assessing high-level transfer pricing risk and other base erosion and profiting shifting-related risks. 

With these new measures, it is anticipated that there will be an increase to the number of tax audits conducted by Greek tax authorities (and similarly by foreign tax authorities). Thus, it will be critical that the information contained in the CbC report be accurate so as to reduce the risk of disputes with the tax authorities regarding the MNE group’s transfer pricing policy.

 

Read an October 2017 report [PDF 471 KB] prepared by the KPMG member firm in Greece

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