close
Share with your friends

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.

1000

Related content

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

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us

 

Want to do business with KPMG?

 

loading image Request for proposal