A radical decision was taken by the Greek Parliament with the adoption of Article 171 of Law 4972/2022.
The Official Gazette dated September 23 paves the way for reverse reforms that reduce the tax results of affiliated Greek entities.
A prerequisite for the application of the above is a finalized tax audit in the part where an equal taxable results increase has been performed and additional tax has been discharged.
The other party to the transaction can then file an amended income tax return, including a reverse tax adjustment, but the audit report of the first taxable person must be filed together.
More specifically it states: "Exceptionally, if according to par. 1, the profits of a legal person or legal entity, which are subject to tax in Greece, include profits which are subject to tax in Greece in the name of a related person within the meaning of article 2 and have arisen following a tax audit of the first taxable legal person or legal entity, the second taxable person, related legal person or legal entity may request a corresponding adjustment to its taxable profits, upon submission of an amending tax return accompanied by notification of the relevant audit report of the first taxable person."
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