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
Β) Institutional Framework for Double Taxation Avoidance Agreements
Section C of International Administrative Cooperation
Α) Directive 2011/16/ΕΕ as amended and in force
- Directive 2011/16/EU on administrative cooperation in the field of taxation and following the repeal of Directive 77/779/EEC. Incorporation into Greek law by Law 4170/2013 part one, Articles 1-25 (Government Gazette 163A/12-7-2013).
- 1st amendment with Directive 2014/107/EU on the mandatory automatic exchange of information in the tax sector. Incorporation into the Greek legislation with Law 4378/2016, part one, chapter A', articles 1-4 and chapter B', article 7 (Government Gazette 55A/5-4-2016).
- 2nd amendment with Directive (EE) 2015/2376, to amend Directive 2011/16/EU regarding the mandatory automatic exchange of information in the tax sector.Incorporation into the Greek legislation by Law 4474/2017, chapter A, articles 1-6 (Government Gazette A' 80/07-06-2017).
- 3rd amendment with Directive (EU) 2016/881, to amend Directive 2011/16/EU regarding the mandatory automatic exchange of information in the tax sector. Incorporation into the Greek legislation by Law 4484/2017, part one, articles 1-9 (Official Gazette A΄110/01-08-2017).
- Circular 1131/2017
Β) Taxation of income from savings in the form of interest
- Directive 2003/48/ΕΚ of the Council of June 3rd, 2003 on taxation of income from savings in the form of interest.
Incorporation 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 established in Directive 2003/48/EC on the taxation of savings income with third countries or the associated or dependent territories of the EU and Amending Protocols:
9. The Principality of Liechtenstein
-Agreement between the EC- The Principality of Liechtenstein which provides for measures equivalent to those established in Directive 2013/48/ΕΚ for taxation of income from savings in the form of interest. – Sanction with Law 3365/2005 (OGG Α’ 161/23-06-2005)
-Amending Protocol – Sanction with Law 4516/2018 (OGG Α’ 19/07-02-2018)
10. The Republic of San Marino
- Agreement between the EC- The Principality of Liechtenstein which provides for measures equivalent to those established in Directive 2013/48/ΕΚ for taxation of income from savings in the form of interest. – Sanction with Law 3362/2005 (OGG Α' 158/2306-2005)
-Amending Protocol – Sanction with Law 4515/2018 (OGG Α’ 18/07-02-2018)
- Directive 2060/2015/EU on the repeal of Directive 2003/48/EC on the taxation of savings income in the form of interest. Incorporation into the Greek legislation with Law 4378/2016, part one, chapter B, articles 5-7 (Government Gazette 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 (Circular 1140/2005).
- Information exchange format for the submission of data by 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 (Government Gazette 1671/tB'/2005 Ministerial Decision (Circular 1141/2005)
- Circular 1078/2016: Notification of the provisions of Article 5 of Law 4378/2016 (Government Gazette 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 issues and its Amendment Protocol.
D) FATCA Greece – USA Agreement and application provisions
- Sanction with Law 4493/2017 (OGG Α' 164/31-10-2017)
- Α.1109/2020: extension of the deadline for subsmission of information or zero reports for the year 2019
- Circular 1094/2018
Ε) Multilateral Agreement of the Competent Authorities 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 Agreement of Competent Authorities for the Exchange of Reports by Country and implementing provisions
I) Greece - USA Agreement on the exchange of country-by-country reporting and implementing provisions.
J) Agreement between the Greek Government and the State of Guernsey on the exchange of tax information.
K) Determination of non-cooperative states (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