Greece: APA rollback rules are expanded

Greece: APA rollback rules are expanded

Newly enacted law 4714/2020 amends the advance pricing agreement (APA) rollback rules in Greece.


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Law 4714/2020 amends existing APA provisions (Article 22 of law 4174/2013) to comply with the “minimum standard” under Action 14 of the OECD’s base erosion and profit shifting (BEPS) project relating to the rollback rules for APAs. The new provisions are effective as of 1 January 2014.

The new measures provide: 

  • An application for a bilateral or multilateral APA may include a request for a rollback of the APA to prior tax years, as long as the facts supporting the APA are identical to the facts from the prior years for which the statute of limitation has not expired and for which no tax audit mandate has been issued to the taxpayer.
  • A request for a rollback of the APA may also be made in instances when there are pending applications for a bilateral or multilateral APA.
  • Amended tax returns that must be submitted for prior years as a result of an APA will be treated as timely filed if they are submitted within 30 days from the date of notification to the taxpayer in relation to the issuance of the APA.

Read an August 2020 report [PDF 411 KB] prepared by the KPMG member firm in Greece

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