Issues of International tax content
Here you can find all the relevant information and documents regarding the Double Taxation Avoidance Agreements and the International Administrative Cooperation, as well as the corresponding institutional framework.
Department A of International Tax Treaties and Mutual Agreement Procedures
Α) Documents for the Application of Double Taxation Avoidance Agreements
Β) Institutional Framework for Double Taxation Avoidance Agreements
Department B of International Administrative Cooperation in the Field of Taxation
A) Directive 2011/16/ΕU as amended and in force
- 1ηamendment with Directive 2014/107/EU as regards the mandatory automatic exchange of information in the field of taxation. Transposition into the Greek legislation with Law 4378/2016, part one, chapter A', articles 1-4 and chapter B', article 7 (OGG 55A/5-4-2016).
- 2nd amendment with Directive (Eu) 2015/2376 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation. Transposition into the Greek legislation by Law 4474/2017, chapter A, articles 1-6 (OGG A' 80/07-06-2017).
- 3rd amendment with Directive (EU) 2016/881 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation. Transposition into the Greek legislation by Law 4484/2017, part one, articles 1-9 (OGG A΄110/01-08-2017).
o Circular 1131/2017
Β)Regulatory framework for the automatic exchange of financial account information
- Directive 2003/48/ΕC of the Council of June 3rd, 2003 on taxation of savings income in the form of interest payments. Transposition in the Greek legislation with Law 3312/2005, provisions of Chapter Β΄ (OGG 35Α /16-2-2005)
- Agreements / Conventions for the implementation of equivalent measures to those laid down in Directive 2003/48/EC on the taxation of savings income in the form of interest payments with third countries or the associated or dependent territories of the EU and Amending Protocols:
1. Guernsey, Isle of Man, Jersey
2. The Netherlands Antilles and Aruba
3. Anguilla
6. Montserrat
9. The Principality of Liechtenstein
Agreement between the EC- The Principality of Liechtenstein providing for measures equivalent to those laid down in Directive 2013/48/ΕC for taxation of savings income in the form of interest payments. Ratification with Law 3365/2005 (OGG Α’ 161/23-06-2005)
-Amending Protocol - Ratification with Law; 4515/2018 (OGG Α’ 18/07-02-2018)
10. The Republic of San Marino
Agreement between the EC- The Republic of San Marino providing for measures equivalent to those laid down in Directive 2003/48/ΕC for taxation of savings income in the form of interest payments. - Ratification with Law 3362/2005 (OGG Α' 158/2306-2005)
Amending Protocol – Ratification with Law 4516/2018 (OGG Α’ 19/07-02-2018)
11. The Principality of Monaco
12. The Principality of Andorra
- Directive (EU) 2060/2015 repealing Directive 2003/48/EC on the taxation of savings income in the form of interest payments.
Transposition into the Greek legislation by Law 4378/2016, part one, chapter B, articles 5-7 (OGG A' 55/5-4-2016) - Circular 1082/2006: Circular for the interpretation of the provisions of Chapter B of Law 3312/2005
- Certificate of Tax Residence for interest payments (Circular 1140/2005).
- Exchange of Information schema for the filing of data by the payment institutions to the competent authorities (Circular 1141/2005)
- Definition of evidence for UCITS (Circular 1012/2006). . - Circular 1078/ 2007: Amendment of no. 1109637/2412/05/DOS/2005 (OGG 1671/vB'/2005 Ministerial Decision (Circular 1141/2005)
- Circular 1078/2016: Notification of the provisions of Article 5 of Law 4378/2016 (OGG A' 55) regarding the repeal of Articles 3 to 13 of Law 3312/2005, subject to the validity of some of them.
C) Convention of the Council of Europe and the Organization for Economic Cooperation and Development (OECD), regarding mutual administrative assistance in tax matters and its Amendmending Protocol.
D) FATCA Agreement between Greece – USA and implementing provisions
- Ratification with Law 4493/2017 (OGG Α' 164/31-10-2017)
- Α.1109/2020: deadline extension for filing data or zero reports for the year 2019
- Circular 1094/2018
E) Multilateral Competent Authorities Agreement for the Automatic Exchange of Financial Account Information and implementing provisions.
F) Regulatory framework for the automatic exchange of financial account information
G) Information material for the automatic exchange of financial account information
H) Multilateral Competent Authorities Agreement for the Exchange of Country by Country Reporting and implementing provisions
I) Agreement between Greece - USA on the exchange of Country-by-Country reporting and implementing provisions.
J) Agreement between the Hellenic Republic and the State of Guernsey on the exchange of information on tax matters.
Κ) Ministerial Decisions of non-cooperative jurisdictions (Article 65 par. 3 of Law 4172/2013)
L) Manual on International Administrative Cooperation in the field of direct taxation.
- E. 2042 /21-06-2023
- Form of information exchange request
- Form of spontaneous information exchange
- Form of request for disclosure of documents
- Form of feedback
Relevant links of International Administrative Cooperation
- Convention of the Council of Europe and the Organization for Economic Cooperation and Development (OECD) on Mutual Administrative Assistance in Tax Matters and Amending Protocol
- Explanatory notes
- List of participating states and jurisdictions
- List of declarations/ reservations
- Website of the European Commission on administrative cooperation in the field of direct taxation:
- OECD’s website for the automatic exchange of information
- OECD Frequently Asked Questions (FAQs) on the implementation of the Common Reporting Standard (CRS)
- OECD Peer Review Report on the Automatic Exchange of Financial Information (2020)
- US Frequently Asked Questions (FAQs) on the implementation of FATCA legislation
- Commentary notes on Article 26 (Exchange of Information) of the OECD Model Tax Convention for the Avoidance of Double Taxation relating to taxes on income and on capital
- Information regarding technical support in issues of International Administrative Cooperation