Greece opens separate domestic and IIR/UTPR top-up-tax returns

Two tax returns, not one combined form

Decisions A.1236/2026 and A.1237/2026, dated 30 October and published in Gazette issues B 6587 and B 6588 on 2 November, prescribe separate returns. The first concerns domestic top-up tax under article 12; the second concerns the Income Inclusion Rule and Undertaxed Profits Rule. Their annexes establish different form content, while article 49 supplies the statutory tax-return framework. This is an operational filing development, not a new minimum-tax charge.^[1][2][3][5]

Identify the filer before completing the form

For domestic top-up tax, A.1236 generally uses the designated local entity where several domestic constituent entities exist, but requires separate domestic-member returns in its specified joint-venture and minority-owned cases. A.1237 distinguishes the domestic ultimate parent or designated filing entity for IIR from the domestic constituent entity or designated local entity for UTPR. Both decisions require an obliged entity to file even where no top-up tax arises. A nil calculation is therefore not, by itself, a filing exemption.^[2][3]

Keep the information return and payment separate

AADE directs filers to myAADE for both tax-return categories. The decisions state that the tax returns are due by the last working day of the month following the GIR deadline. Specifically for MNE or large-scale domestic groups whose reporting fiscal year ends on or before 31 March 2025, AADE states 30 November 2026 for these tax returns and 31 December 2026 for payment. These dates must not be applied indiscriminately to later fiscal years.^[1][4]

Practical action

Group tax teams should reconcile the Greek entities, designated filer, reporting year and applicable tax-return category before submission through myAADE. Confirm whether a separate-member exception applies, preserve the submitted return and payment evidence, and track GIR completion independently. The availability of both applications does not establish that every Greek company owes tax under both rules or that a foreign GIR filing satisfies the Greek tax-return obligation.^[2][3][4][5]