Country-by-Country reporting(CBC)/DAC4

On 19 July 2013 the Organization for Economic Co-operation and Development (OECD) published its Action Plan on Base Erosion and Profit Shifting (BEPS Action Plan), which is a major initiative to amend existing international tax rules. The work on Action 13 of the BEPS Action Plan resulted in a set of standards for the provision of information on PE Groups, including the Core Documentation File, the Greek Documentation File and the Country-by-Country Report. It is therefore appropriate to take OECD standards into account when establishing the Country Report rules.

Law 4490/2017 ratified the accession of Greece to the Multilateral Agreement of Competent Authorities (MPAA) for the Exchange of country-by country reporting by Multinational Business Groups.

In addition, the Eu Council issued EU Directive 2016/881 (commonly known as "DAC4"), which amends Directive 2011/16/EU and expands the scope of the automatic exchange of information in the field of taxation by regulating the mandatory automatic exchange of Country Reports at the level of EU countries.

Law 4484/2017 established the scope and conditions for the submission of the Country by Country Report in Greece by Multinational Business Groups.

A Bilateral Competent Authorities Agreement has been concluded between Greece and the USA for the exchange of Country Reports (CAA on CbC), which was signed by the of IAPR’S Commander in Oslo on 27.09.2017. The ratification of this Agreement is expected upon passing of a relevant law in the Parliament.

Law 4534/2018 (Α΄77) established the obligation to submit country by country reports in accordance with the Greece-US Bilateral Agreement. Submission is made through the existing application for submission of Country by Country Reporting, with a closing date of May 31, 2018.