New tax treaty with Republic of Singapore including article 25 of OECD Model in line with requirements of Action 14 (entry in force 01/01/2023).
New tax treaty with Republic of France (replaced the older one) including article 25 of OECD Model in line with requirements of Action 14 (signed: 11/05/2022, ratified by Hellenic Parliament: 25/10/2022, entry in force is pending according to art. 29, par. 1 of the treaty).
Termination of the tax treaty with the Kingdom of Sweden (not applicable since 01/01/2022).
Making Dispute Resolution Mechanisms More Effective – Consolidated Information on Mutual Agreement Procedures 2023
OECD/G20 Base Erosion and Profit Shifting Project
Greece
Recent developments relating to MAP in Greece prior to 15 August 2023
Developments relating to MAP in the tax treaty network
Other developments relating to MAP
Publication of the Decision no. 1226/2020 with subject: “Regulation of issues regarding the MAP in accordance with the bilateral Conventions for the Avoidance of Double Taxation on Income” in English language.
Updated guidelines of MAP procedure and manual with “Frequently Questions and Answers” (in process- publication on Tax Administration’s site after the conclusion of internal procedures).
Latest Action 14 Peer Review report
25 May 2021 - https://doi.org/10.1787/3bb76f22-en
Tax treaty network of Greece
57 treaties, applicable to 58 jurisdictions (covering all treaties signed, although not necessarily in force)
status of MLI: in force.
Table 1. State of play of Greece's tax treaty network
Source: OECD
Greece's MAP programme
Organisation of competent authority function
eight persons:
two heads of unit
six persons working on MAP cases (all of which work on other tasks as well):
one person works on attribution/allocation cases and five persons work on other cases.
contact persons for MAP requests:
for attribution / allocation cases: Independent Authority for Public Revenue
Directorate General for Tax Operations: Directorate for Audit Business Planning, Section D΄ Transfer Pricing-MLCs and Special Audits Department
Address:1, Chandri & Thessalonikis Τ.Κ. 183 46, Moschato, Greece
Tel. No: +30 210 4802688 Email: diesel04@aade.gr.
for other cases: Independent Authority for Public Revenue
Directorate General for Taxation: Directorate for International Tax Relations- International Tax Treaties and MAP’s Department
Address: 8, Karageorgi Servias Str., 101 84, Athens, Greece
Tel. No: +30 210 3375580, Email: dos.a@aade.gr.
Figure 1. Competent Authority Organisational Structure
Source: OECD
Table 2. Guidance on the MAP process
Overview of Greece's MAP Statistics for 2022
Please refer to https://www.oecd.org/tax/dispute/map-statistics-greece.pdf for details with respect to Greece's MAP Statistics.
Figure 2. Cases closed in 2022
Source: OECD
Figure 3. Evolution of Greece's MAP caseload (2016-22)
Source: OECD
Table 3. Overview of Greece’s MAP caseload for 2022
Source: OECD
Table 4. Greece’s average time to resolve MAP cases in 2022
Source: OECD