The Greek Ministry of National Economy and Finance is moving forward with two major tax changes that are expected to have an immediate impact on the business environment, with the introduction of the Group Taxation and the Advanced Tax Rulings.

These reforms aim to reduce tax uncertainty and create a more flexible and predictable tax framework for businesses.

The Ministry of Finance is considering adopting for the first time the Group Taxation system. The new framework will allow corporate groups to file a single tax return for all their subsidiaries, facilitating compliance with tax obligations and enhancing transparency. In this way, companies will be able to balance losses and profits between their companies, reducing their tax burden and improving their financial stability.

Group Taxation is already in place in several European countries, allowing groups to operate more flexibly and strengthen their overall financial position. The Greek Ministry of Finance aspires to align the new system with international standards, enhancing the competitiveness of Greek companies.

For example, a group with five subsidiaries in Greece, of which three are profitable and two are loss-making, will be able to offset the results of all its companies, reducing its overall tax burden. Under the current system, each company is taxed separately, with no possibility of internal offsetting.

With the implementation of Group Taxation, the group will be able to use the losses of its subsidiaries to reduce the taxable income of its profitable companies, improving the liquidity and competitiveness of the companies.

Meanwhile, by the end of the year, the Ministry of Finance plans to complete the process for the issuance of Advanced Tax Rulings. This is a tool that will allow companies to obtain preliminary clarification on the tax treatment of specific transactions or business structures, thus reducing tax uncertainty.

The move is expected to boost the confidence of investors and create an environment of stability, which is critical for growth and attracting new investment. With a clearer and more predictable tax framework, businesses will have greater freedom to plan their future moves and make strategic investments.

Already, with Law 5100/2024, Greece has adapted the income taxation of multinationals and large domestic groups to the requirements of the European Directive 2022/2523, harmonizing its tax regime with modern international standards. This change is aimed at eliminating distortions and creating conditions of equal competition between Greek and European companies.

Harmonization with European guidelines will allow Greece to strengthen its tax administration, ensuring business compliance without imposing excessive tax burdens.