Greece joined the Global Forum in 2009. Greece underwent its Second Round of EOIR Peer Review in 2020 (Greece’s 2020 Report),1 which assessed its legal and regulatory framework in force as at 5 May 2020 and its practical implementation, including in respect of EOI requests received and sent during the review period from 1 January 2016 to 31 December 2018. Greece received an overall rating of Largely Compliant and the individual Elements were rated as follows:
Enhanced Monitoring Report on the Implementation of the Standard on Transparency and Exchange of Information on Request 2025
Report
Table of contents
Share
Facebook
Twitter
LinkedIn
Greece
Copy link to Greece|
A.1 |
A.2 |
A.3 |
B.1 |
B.2 |
C.1 |
C.2 |
C.3 |
C.4 |
C.5 |
Overall |
|
|---|---|---|---|---|---|---|---|---|---|---|---|
|
Determinations |
i.p.b. |
i.p. |
i.p. |
i.p. |
i.p. |
i.p. |
i.p. |
i.p. |
i.p. |
n.a. |
LC |
|
Ratings |
PC |
LC |
C |
C |
C |
C |
C |
C |
C |
LC |
Status of implementation of recommendations in the peer review report
Greece received eight in-box recommendations in relation to Elements A.1, A.2 and C.5.
This monitoring report assesses the actions taken by Greece to address the recommendations issued in its EOIR Peer Review Report and the peer input received for the monitoring period 2023-2024.
The report concludes that one recommendation is “considered provisionally addressed in the context of the monitoring process, subject to detailed validation”, five recommendations are “in the process of being addressed” and two recommendations “have not been addressed”, and it advises on actions required.
Element A.1: Availability of ownership information
1. Identity of holders of bearer shares of shipping companies and shipping companies of recreational boats
|
Recommendation (A.1, framework) |
Greece should ensure that in respect of shipping companies and shipping companies of recreational boats (NEPAs) owners of bearer shares are always identified. |
|
Underlying factor |
Although there are many instances where the holders of bearer shares of shipping companies and of shipping companies of recreational boats (NEPAs) must be identified, including all cases where such shares are transferred, there can be situations where identity information on bearer share holders of such companies may not be available. (see paragraphs 117-122 of the Greece’s 2020 Report for more information) |
|
Summary of actions reported |
Greece passed a new law on shipping companies of recreational boats in 2022. Under its provisions, shipping companies of recreational boats are permitted to issue only registered shares. A transitional period to convert existing bearer shares was provided until the end of 2023 to allow shipping companies of recreational boats that had issued bearer shares to convert them into registered shares. The relevant department of the Ministry of Maritime Affairs and Insular Policy that oversees shipping companies of recreational boats has monitored the conversion of bearer shares. Of the approximately 2 000 active shipping companies of recreational boats, around 1 920 have converted their bearer shares into registered shares. Greece has indicated that certificates of registration are issued only to those shipping companies of recreational boats that are found compliant with the requirements. In respect of shipping companies, the governing law has not yet been amended. Greece has indicated that a study of its amendment is now in its final stages. Transitional provisions will be determined with the aim of ensuring a smooth conversion of all bearer shares of shipping companies into registered shares. |
|
Conclusion |
Greece has made progress to address the recommendation. Since 2022, due to amendments in the applicable law, shipping companies of recreational boats can only issue registered shares and were required to convert existing bearer shares into registered shares by end-2023. While Greece has provided indicative details of compliance with the new obligations, clear statistics indicating compliance levels and supervisory measures are missing. For shipping companies of recreational boats, statistics on active entities have been provided. It is unclear how many of the inactive shipping companies of recreational boats had issued bearer shares and continue to retain legal personality and whether identity of owners of their bearer shares is known. On shipping companies, there has been no material progress yet. Greece should report substantive progress in the next self-assessment. |
|
Status determined |
In the process of being addressed |
|
Actions required |
In the next self-assessment in 2028, Greece should:
|
2. Legal ownership of shipping companies of recreational boats (NEPAs) and penalties for non-maintenance of legal ownership by shipping companies and shipping companies of recreational boats
|
Recommendation (A.1, framework) |
Greece should ensure that legal ownership of shipping companies of recreational boats (NEPAs) is available, and in so far as there are no penalties provided, Greece should introduce effective sanctions for shipping companies and NEPAs [shipping companies of recreational boats] where they fail to maintain ownership information. |
|
Underlying factor |
In respect of shipping companies of recreational boats (NEPAs), there is no requirement on such companies to maintain a book of shareholders or any associated penalty for non-maintenance. Further, there are no penalties on shipping companies for not keeping a book of shares and shareholders. (see paragraphs 61-62 and 70 of Greece’s 2020 Report for more information) |
|
Summary of actions reported |
Law 4926/2022 enacted in 2022 provides a new institutional framework for shipping companies of recreational boats . A new online publicly accessible application (e-NEPA) has been operationalised, through which all shipping companies of recreational boats are incorporated electronically since 2022. Articles of incorporation, minutes of board meetings and of general assembly meetings must be submitted on this portal. Certain commercial certificates required by shipping companies of recreational boats for day-to-day commercial operations are obtained only from the portal, and for this, compliance with filing requirements is necessary. In addition, under the provisions of Article 33 of Law 4926/2022, all transfers of shares of shipping companies of recreational boats must be recorded in the shareholder register. Only the shareholders in the shareholder register of shipping companies of recreational boats can enjoy shareholder rights. Further, shipping companies of recreational boats are required to submit their beneficial ownership information to the Central Beneficial Ownership Register. Sanctions apply if beneficial ownership information is not maintained by shipping companies of recreational boats. |
|
Conclusion |
Greece has made progress to address the recommendation The new legal framework for shipping companies of recreational boats requires them to maintain shareholder registers and accords shareholder rights to those registered in them. However, it is not known if this will ensure availability of legal ownership information for five years in line with the standard for shipping companies of recreational boats that cease to exist. The online portal replaces the manual system for shipping companies of recreational boats that existed at the time of the 2020 Report, as information that was earlier submitted manually is now submitted electronically. It is unclear whether the scope of information submitted has changed and whether complete legal ownership information of shipping companies of recreational boats is available under the new system (an aspect found deficient in the 2020 Report). Moreover, the new portal applies to new incorporations and no information is provided on the status of pre-2022 incorporated shipping companies of recreational boats. No sanctions for non-maintenance of book of shareholders by shipping companies or shipping companies of recreational boats have been introduced. The requirements for beneficial ownership information and the applicable sanctions for non-compliance do not fully compensate for deficiencies on availability of legal ownership information. Greece is urged to make substantive progress before the next self-assessment. |
|
Status determined |
In the process of being addressed |
|
Actions required |
In the next self-assessment in 2028, Greece should:
|
3. Legal ownership information on foreign companies with sufficient nexus
|
Recommendation (A.1, framework) |
Greece should ensure that legal ownership information on foreign companies having sufficient nexus with Greece is always available. |
|
Underlying factor |
Foreign companies having sufficient nexus with Greece are not obliged to maintain ownership information in all circumstances. (See paragraph 80 of the Greece’s 2020 Report for more information) |
|
Summary of actions reported |
Greece has placed reliance on its existing Tax Procedure Code and its relevant provisions contained in articles 10 and 11 that require all natural and legal persons to register with the tax authorities whenever they are liable to tax or responsible for withholding taxes. Greece considers that as part of the requirements, a foreign company engaging in business in Greece would be required to file its statutory documents from the jurisdiction of incorporation. |
|
Conclusion |
No progress has been reported on addressing the recommendation. Greece’s submissions have already been considered in the peer review report and were found insufficient to ensure the availability of legal ownership information on foreign companies with sufficient nexus to Greece. Greece is urged to address the recommendation and report substantive progress in its next self-assessment. |
|
Status determined |
Has not been addressed |
|
Actions required |
Greece should submit a schedule for the completion of actions to address the recommendation and an update on its progress made to address the recommendation by 31 March 2026. |
4. Monitoring conversion of bearer shares to registered shares for Sociétés Anonymes
|
Recommendation (A.1, practice) |
Greece is recommended to continue monitoring the application of new Law 4548/2018 that prohibits the issuance of bearer shares by Sociétés Anonymes (SAs) and requires all issued bearer shares to be converted into registered shares by 31 December 2019 and to effectively enforce sanctions on non-compliant SAs [Sociétés Anonymes]. |
|
Underlying factor |
Although Greece has recently introduced the new Law 4548/2018 to prohibit issuance of bearer shares by Sociétés Anonymes (SAs) and to direct the conversion of issued bearer shares into registered shares, the conversion requirements need to be monitored and penal provisions need to be effectively enforced. (See paragraphs 112-116 of Greece’s 2020 Report for more information) |
|
Summary of actions reported |
Greece authorities confirm that there are no outstanding bearer shares issued by Sociétés Anonymes. The relevant process monitored by the General Commercial Registry held by the Ministry of Development has been completed in 2020 and according to the statistical data of the Business Register, there are no operating public limited companies that hold bearer shares. The authorities have noted that the relevant provisions of para 1-7 of article 184 of Law 4548/2018 regulated the regime of the gradual conversion of the bearer shares of Sociétés Anonymes into registered/nominal shares in a short period of time in order for shareholders to be able to exercise their rights. In order to strengthen the existing provisions and compel all companies to comply with the new requirements, in July 2020, a legislative amendment was made to introduce paragraph 8 to article 184 of Law 4548/18 (article 93 of Law 4717/31-07-2020) which provides for the forced conversion of the shares. This was accompanied by a circular issued in September 2020 by the Companies Directorate of the Ministry of Development. Pursuant to the provisions of article 184 of Law 4548/2018 and this circular, all bearer shares issued by Sociétés Anonymes were converted into registered shares. |
|
Conclusion |
Greece has made progress to address the recommendation. The legislative amendments for forced conversion of existing bearer shares and the conclusions that there are no more bearer shares issued by Sociétés Anonymes in Greece are encouraging developments. However, Greece should provide supporting details to sufficiently reflect the activities undertaken by the supervisory authorities to achieve the outcome reported. It should report further details in the next self-assessment. |
|
Status determined |
In the process of being addressed |
|
Actions required |
In the next self-assessment in 2028, Greece should:
|
5. Effective implementation of the central beneficial ownership register
|
Recommendation (A.1, practice) |
Greece is recommended to ensure the full effective implementation of the Central Register of Beneficial Owners and to put in place the necessary supervisory and enforcement mechanism to monitor compliance of all legal persons and arrangements to ensure that adequate, accurate and up-to-date beneficial ownership information is available. |
|
Underlying factor |
The newly set up Central Register of Beneficial Owners will be an important source of beneficial ownership information for Greek Authorities. Effective monitoring and supervision of the obligations of maintaining adequate, accurate and up-to-date beneficial ownership information by all legal entities and arrangements and uploading such information to the Central Register would be key to effective implementation. This would be especially so for ensuring availability of beneficial ownership information on inactive companies. The Central Register has still not been fully operationalised. Furthermore, although the sanctions and penalties have been provided for not providing information to the Central Register, there is lack of clarity on the overall supervisory and enforcement mechanism and responsibilities. (see paragraphs 94-98 and 108 of the Greece’s 2020 Report for more information) |
|
Summary of actions reported |
Dedicated Ministerial Decisions issued in 2022 operationalise the Central Register of Beneficial Owners and cover aspects of access rights, fees, data recording and audit procedures. The Ministry of Economy and Finance oversees the Register. Access to it is governed through the tax credentials of entities. Automatic cross-checks with information in tax databases are carried out. The Ministry of Economy and Finance and the Tax Administration have carried out awareness raising actions. Entities can update the information in the Register. Tax auditors have access to it and can cross-check the information during their audits. A dedicated Joint Ministerial Decree issued in 2023 has formalised the audit procedures for the information contained in the Central Register of Beneficial Owners. A Handbook for Auditors has been published. In the second half of 2023, 291 audits were carried out by the relevant audit department of the Ministry of Economy and Finance, resulting in identification of 40 violators with 41 violations. Sanctions imposed amounted to more than EUR 131 000. The violations concerned 40 cases of non-submission of declarations to the Central Register of Beneficial Owners and 1 case of inaccuracy in the data submitted to the Central Register of Beneficial Owners. In 2024, through 765 audits, 133 violators with 174 violations were detected. Total sanctions exceeding EUR 786 000 were imposed. The violations concerned 168 cases of non-submission of declarations to the Central Register of Beneficial Owners and 6 cases of inaccuracies in the data submitted to the Central Register of Beneficial Owners declaration. |
|
Conclusion |
Greece has made progress to address the recommendation. Through suitable Ministerial Decisions, the Central Register of Beneficial Owners has been operationalised since 2022. Some actions have also been taken to supervise and check the accuracy of information in the Register. While encouraging, information on the level of compliance by different types of legal entities and arrangements with the requirement to submit beneficial ownership information to the Register, updating such information, and follow-up actions on discrepancies noted in the reported information are not available. Greece should report further progress in the next self-assessment. |
|
Status determined |
In the process of being addressed |
|
Actions required |
In its next self-assessment in 2028, Greece should provide:
|
Element A.2: Availability of accounting information
6. Reliable accounting records of foreign trusts with Greek resident administrators or trustees
|
Recommendation (A.2, framework) |
An obligation should be established to maintain reliable accounting records, including underlying documentation for trusts with Greek-resident administrators or trustees in all circumstances. |
|
Underlying factor |
Greek legislation does not ensure that reliable accounting records or underlying documentation are kept in all circumstances for foreign trusts with Greek-resident administrators or trustees. (see paragraph 164 of the Greece’s 2020 Report for more information) |
|
Summary of actions reported |
No progress has been reported by Greece |
|
Conclusion |
No progress has been reported on addressing the recommendation. Greece is urged to address the recommendation and report substantive progress in its next self-assessment. |
|
Status determined |
Has not been addressed |
|
Actions required |
Greece should submit a schedule for completion of steps to address the recommendation and an update on its progress made to address the recommendation by 31 March 2026. |
7. Availability of accounting records of shipping companies and shipping companies of recreational boats
|
Recommendation (A.2, practice) |
Greece should ensure that all shipping companies, including those that do not have accounting record-keeping requirements in their deeds of incorporation, and NEPAs [shipping companies of recreational boats] always have their accounting records with underlying documentation available. |
|
Underlying factor |
Shipping companies are obliged to maintain accounting records if their incorporation deed requires the same. Although requirements of tax law would be applicable to all entities carrying on business, it is not clear that the tax law obligations are adequately monitored and accounting information with underlying documents is available for shipping companies and NEPAs [shipping companies of recreational boats]. (see paragraphs 180-181 of Greece’s 2020 Report for more information) |
|
Summary of actions reported |
Greece has submitted that shipping companies of recreational boats now have accounting obligations. Law 4926/2022 enacted in 2022 provides a new institutional framework for shipping companies of recreational boats. The keeping of accounting records for all shipping companies of recreational boats is now mandatory (article 52 paragraph 2). Different types of shipping companies of recreational boats have different levels of obligations to maintain accounting records. The shipping companies of recreational boats that manage or operate commercial recreational boats owned by third parties must keep accounting records using a double-entry system and have all the obligations arising from the Accounting Law (Law 4308/2014). The shipping companies of recreational boats that are shipowners of commercial recreational boats must maintain a single-entry accounting system in the Greek language, to issue, receive and keep the documents of their transactions. They are also required to submit the required declarations and tax data to the Head of the competent Local Tax Office. Further, for certain types of shipping companies of recreational boats that operate a specified category of ships, some simpler accounting obligations under the Accounting Law have been provided. |
|
Conclusion |
Greece has made progress to address the recommendation. The 2022 law provides further legal basis for maintenance of accounting records by shipping companies of recreational boats, in addition to the pre-existing tax obligations. However, there is some lack of clarity in the application of the new provisions in respect of different types of shipping companies of recreational boats, requirements around underlying documentation and the level of discretion shipping companies of recreational boats have in deviating from maintenance of accounting information. No information was provided on implementation, supervision and enforcement in respect of shipping companies as well as shipping companies of recreational boats, in relation to either the tax obligations or the more specific obligations applicable to them. Greece should report further progress in the next self-assessment. |
|
Status determined |
In the process of being addressed |
|
Actions required |
In the next self-assessment in 2028, Greece should –
|
Element C.5: Effective exchange of information
8. Timeliness of responding to requests
|
Recommendation (C.5, practice) |
Greece should continue its efforts to improve the timeliness of its replies. |
|
Underlying factor |
Peers were in general satisfied with the timeliness and quality of the answers provided by Greece. More than half the requests were answered within 180 days. However, the requested information was not provided in all cases in a timely manner. (see paragraphs 300-306 of the Greece’s 2020 Report for more information) |
|
Summary of actions reported |
Greece has been closely monitoring the timeliness of responses, adhering to its internal policies of providing responses within 90 days. The staff in the EOI unit is experienced and has been adequate to manage the workload. Since the publication of the report in 2020, Greece has been working incrementally on improving its timeliness of providing complete responses. In 2021, 58% of the requests were fully answered within 90 days and cumulatively 74% of the requests were fully answered within 180 days. For 2022, the timeliness further improved with 60% of the requests fully answered within 90 days, and 77% within 180 days. In 2023, 60% of the requests were answered within 90 days while cumulatively 80% of the requests were answered within 180 days. These statistics have further improved in 2024 to 90% and 94% respectively. Over the entire two-year monitoring period (2023-2024), Greece has successfully provided complete responses to 81% of all received requests within 90 days, 90% cumulatively within 180 days and 96% cumulatively within a year. There have been no failures to provide information in any case. |
|
Conclusion |
Greece appears to have taken appropriate actions to address the recommendation. The timeliness of responding to requests has improved considerably and Greece has effectively exchanged information. No issues were raised by Greece’s peers. |
|
Status determined |
Considered provisionally addressed in the context of the monitoring process, subject to detailed validation |
|
Actions required |
In its next self-assessment in 2028, Greece should provide updated timeliness statistics for the corresponding monitoring period, according to paragraph 29 of the Enhanced Monitoring Methodology. |
EOIR experience
Over the monitoring period, Greece received 345 requests and sent 541 requests. Belgium, Norway and Germany were the top three partners in respect of incoming requests. Bulgaria, Cyprus and the United Kingdom were the key partners in respect of outgoing requests. Greece reported providing full and final responses in 97% of all the received requests and indicated 3% as pending requests.
Thirteen members provided peer input on Greece. Of these, one member did not have an EOIR exchange with Greece over the monitoring period. Peers have reported a general level of satisfaction in respect of their EOIR experience with Greece. Three peers noted difficulties in communicating with Greece to obtain clarifications on the outgoing requests received from Greece. In each of these three cases, there were technical issues in communication which were bilaterally resolved.
New developments having a bearing on the EOIR standard
No recent developments that could have a bearing on the EOIR standard (other than those reported to address recommendations) have been reported by Greece or have otherwise come to light.
Next steps
Greece should continue taking actions towards implementing the standard effectively.
The following next steps are expected from Greece:
For recommendations where lack of material progress has been identified for more than three years since the last review, Greece should submit to the PRMG - i) a schedule for completion of steps to address the recommendation and ii) an update, including details on the progress on such recommendations by 31 March 2026
Recommendation 3, on legal ownership information on foreign companies with sufficient nexus (Element A.1).
Recommendation 6, on reliable accounting records of foreign trusts with Greek resident administrators or trustees (Element A.2).
Submit the next self-assessment in 2028 under the second round of enhanced monitoring.
See also Chapter 1 (Scope and methodology), section on “PRMG decisions – Statuses determined and actions required”, which explains the next steps expected on recommendations that are “considered provisionally addressed in the context of the monitoring process, subject to detailed validation”.
Views/response of the monitored jurisdiction
Following the outcomes of the Second Round of the EOIR Peer Review, which led to its overall rating as “Largely Compliant”, Greece continued its efforts to improve its status against the requirements of the global standard, including in respect of element C.5 regarding the timeliness of responding to EOI requests.
Acknowledging that the 2025 Enhanced Monitoring Report accurately reflects the current circumstances in relation to the availability of information and validates the progress made thereto, Greece reaffirms its adherence to the international standards of transparency and exchange of information and reiterates its strong commitment to address the remaining weaknesses in accordance with the set deadlines.
Note
Copy link to Note← 1. OECD (2020), Global Forum on Transparency and Exchange of Information for Tax Purposes: Greece 2020 (Second Round): Peer Review Report on the Exchange of Information on Request, Global Forum on Transparency and Exchange of Information for Tax Purposes, OECD Publishing, Paris, https://doi.org/10.1787/8279749f-en.