Greece

Timeline for B2G e-invoicing Greece has published a timeline to implement B2G e-invoicing in the country in line with the following: 

• As of 1 January 2024, suppliers to all central government agencies will be in scope 
• From 1 June 2024 suppliers to all other government authorities will be scope 
• From 1 January 2025, other government expenses must be invoiced electronically 

The official communication in respect of the same in the Government Gazette can be found here:  https://www.sate.gr/data_source/2022%CE%A5%CE%A0%CE%9F%CE%99%CE%9A-%CE%A6%CE%95%CE%9A6232%CE%92.pdf  You can read more about Greece on our dedicated country-specific page here. 

Tax incentives for companies who elect e-invoicing In practice, we know that governments offer tax incentives as a means of encouraging e-invoicing – and more often than not, this has proven to be an effective measure in spawning e-invoicing across individual EU member States.  Greece has passed legislation on 28 March 2023 which states that companies who opted for e-invoicing within the 2020 tax year will benefit from certain tax incentives until the 2023 fiscal year. Tax incentives are a two-way success: they encourage the growth of e-invoicing and engage taxpayers with the process.   The PDF version of the bill (in Greek) can be accessed via the link below:   https://www.et.gr/api/DownloadFeksApi/?fek_pdf=20230100077   

Greece: Data transmission deadline delay The deadlines for transmitting data to the MyData e-reporting platform in Greece have been subject to some fluctuation.    These deadlines again have been further re-defined by the Greek Tax Authorities, the Independent Authority for Public Revenue (IAPR), via the publication of a new decision.    This decision effectively means that deadlines for transmitting certain data generated in 2021, 2022 and 2023 are postponed.    Currently, standard transmission deadlines remain on target for data generated in 2024.   

Greek Tax Authority (IAPR) – new publication On 31 December 2022, decision A.1188/2022 was released by the Greek Tax Authority (IAPR). The decision establishes significant changes relating to the transmission deadlines and sector-specific requirements relating to electronic data transmission to the IAPR. The below provides a summary of the main changes within the decision:

• Real-time transmission through ERPs: the transmission of data and documents through business management programs will be undertaken in real-time from 1 January 2024
• QR Code: the accounting data using business management programs or the application for issuing and transmitting data on the IAPR website (timologio) could be used to generate a QR code. This QR code should generally contain a link for direct access to a digital service of the myDATA digital platform and will provide an overview of the transmitted document summary
• E-Invoice Service Provider: for certain transactions, the adjustment stage for businesses who opted to issue and transmit documents through an e-invoicing service provider to comply with the MYDATA obligation has been extended for 6 months.

The below link (in Greek) encompasses all the MyData changes: https://www.aade.gr/sites/default/files/2023-01/dt_30.12.2022..pdf

VAT form digitisation The VAT in the Digital Age (ViDA) proposal has dominated the e-invoicing and e-reporting landscape in the past few weeks. In line with this drive for digitisation of the tax process across Europe, we are also seeing multiple countries implement fiscal policies to digitise their own tax procedures, in addition to e-invoicing and e-reporting measures.   Greece is no exception to this, and, with the objective of creating a more efficient and less cumbersome tax process, is now voluntarily offering taxpayers the facility to use pre-completed VAT returns from the start of 2023.  

Update on penalties for non-transmission of retail sales documents and (B2G) e-invoicing The new law 4972/2022 introduces some detailed tax measures regarding penalties for non-transmission of retail sales documents. In addition, it has also introduced provided some additional provisions extending the scope of B2G e-invoicing, which means that the B2G now also apply to e-invoices issued for:

• contracts conducted in the sectors of defense and security,
• public contracts and contracts for projects, preparation of studies and the provision of technical and other related scientific services, supplies and general services,
• concession contracts for projects and services, as well as rules for electronic invoices issued for each category of expenditure of the contracting authorities or contracting bodies.

Tax rate changes from 1st July 2022 Greece is introducing a considerable number of tax rate changes from 1^st July 2022. These are summarised below. For the following goods, the rate is set at 6% until 30 June 2022 but will change to 24% from 1^st July 2022:

• Protective masks and gloves for medicine (to protect against viruses and prevent the transmission of diseases - hospital and private use)
• Soap and other preparations for personal hygiene
• Antiseptic solutions, antiseptic wipes and other antiseptic preparations
• Denatured ethyl alcohol which is intended as a raw material to produce antiseptics
• Pure ethyl alcohol of undenatured agricultural origin with an alcoholic strength of 95%, available bottled for retail sale.

The following goods are currently set at 13% until 30 June 2022 ; this rate will be extended until 31 December 2022:

• Non-alcoholic beverages. The rate of tax on goods of these tariff classes was previously set at 13%.

The following items are set at 13% until 30 June 2022 and will be set to 24% starting from 1^st July 2022:

• The introduction of objects of art, collections or antiquities
• The delivery of specific objects of the artistic value

Relating to specific services, rates can be observed as per the following:

• Movie tickets are set at 13%
• Tickets for theatrical performances and concerts for which the tax rate is set at 6%
• The carriage of persons and their luggage are set at 13%
• Tickets for zoos set at 13% currently
• The operation of cafes, cafes, patisseries, restaurants, steakhouses, wineries and other related businesses, with the exception of entertainment establishments, with the exception of the supply of beverages containing alcohol in any proportion are also set at 13%.

All the above-mentioned services receive the extension until 31 December 2022.

Partial B2G mandate Greece currently does not have a Business-to-Business (B2B) e-invoicing mandate, although in the Business-to-Government terrain, Directive 2014/55/EU made it mandatory for the central government to receive e-invoices from private sector suppliers. However, there has been recent clarification from the Greek tax authorities, the Independent Authority for Public Revenue (IAPR) which has shifted some of the e-invoicing obligations to Greek suppliers. This clarification provides that suppliers who have elected to use Electronic Data Provider Services and have submitted the Declaration of Excusive Data Issuance through a Provider must issue e-invoices. In effect, this imposes a partial B2G mandate on select suppliers.

Further extension of VAT rates on certain products The post-Covid recovery appears to be slow in nature, as reflected through the extension of reduced rate many countries are deploying. Greece has announced a third extension of the VAT rate on certain products, from 24% to 13%. These products include:

• coffee;
• transport;
• non-alcoholic drinks;
• cinemas;
• gyms and dance schools; and
• tourism packages.

The VAT rate was first reduced on 30 June 2020, and subsequently extended on 1 October 2021 and again on 30 June 2022. The reduced rates are expected to last until 1^st January 2023.

Proposed extension of VAT reduction for catering, transport, gyms, cinemas and theatres The extension of the reduced VAT rate for catering, transport, gyms, cinemas and theatres is due to expire in June 2022. However, the Greek government has proposed that this be extended. A precise date has not yet been confirmed. However, the costs of such an extension have been laid bare- to accommodate the extension, the Greek government will need look at other areas of the budget to make up the shortfall, amounting to around 250 – 300 million Euros. Such figures offer an insight into the often-drastic financial costs governments are incurring in their fiscal-related measures, and the ramifications on budget planning.

Extension of reduced rate for certain items Greece has extended the reduced rate of 13% until 30 June 2022 for the following products: • Passenger transport; • Coffee and non-alcoholic beverages; • Cinema; • Tourist packages; • Gyms. Similarly, the 6% reduced VAT rate has also been extended for products required for the protection of Covid-19, until 30 June 2022.

MyData- automatic VAT rebates

The Greek MyData platform went live in October 2021 as a mandatory tax reporting requirement, driven by the need to combat VAT fraud.
The Greek government is striving for enhanced automation of the MyData system. Most Greek businesses will now receive any VAT rebates automatically in a shorter period of time- without the need for tax officials to be involved in the process.
There will be a few exceptions- such as companies with repeated past violations, or high-value rebates- which will need to be subject to additional monitoring. However, this shows the Greek Government’s intention to streamline the VAT rebate process and create a more automated MyData platform- resulting in increased convenience for customers and a more customer-friendly solution.

Upcoming MyData changes

Greece is looking to implement a phased roll-out of its upcoming e-invoicing MyData changes, starting on 1^st September 2021. As a reminder, e-invoicing in this context refers to the connection of a certified e-invoicing certified service provider to the MyData platform. Tungsten does not meet the requirements for a certified provider, so we are requesting that suppliers attach their legal invoice to our Tungsten solution as we won’t be able to create the legal artefact for suppliers once the changes take effect.

Here are some key dates to watch out for:

• 1 September 2021: Companies will proceed on a phased basis from this date around the electronic transmission to MyData and the interconnection specifically of cash registers with Greek electronic system. This will be based on the type of their accounting books and annual revenues;
• 1 October 2021: The mandatory transmission of business documents to the MyData platform becomes mandatory;
• From 1 October 2021 onwards, the following businesses must send their accounts receivable documents (i.e. invoices) which they issue:
  • Businesses with double-entry accounting books with a turnover of over € 50.000.
  • Businesses with single-entry accounting books with a turnover of over € 100.000.
• 1 November 2021: all other companies must submit their invoices.

The Greek MyData changes have been delayed multiple times already. So far we have not heard anything to indicate that these changes will not be going ahead on 1 September 2021. We will keep you updated.

Greek government mandate delayed for THIRD time

The Greek government have delayed mandatory invoice registration for ALL businesses through their myDATA platform. The new date floated for mandatory invoice registration through the myDATA platform is Autumn (anticipated October).

6% Reduced VAT Rate for Streaming Theatrical Performances and Concerts

The Greek Public Revenue Authority (AADE) has recently published a Circular regarding the reduced VAT rate for tickets for streaming theatrical performances and concerts.
As of 11 March 2021, the 6% reduced VAT rate will apply for tickets for access to live streaming of such events. The new rate will apply for as long as the measure suspending public attendance to such events is in effect.

6% Reduced VAT Rate for Streaming Theatrical Performances and Concerts

The Greek Public Revenue Authority (AADE) has recently published a Circular regarding the reduced VAT rate for tickets for streaming theatrical performances and concerts.
As of 11 March 2021, the 6% reduced VAT rate will apply for tickets for access to live streaming of such events. The new rate will apply for as long as the measure suspending public attendance to such events is in effect.

Mandatory transmission of tax documents’ data to myDATA platform postponed to July 1st, 2021

The start date for the mandatory transmission of tax documents’ date has already been postponed several times, with the last postponement to 1 July 2021.
It is important to note than none of the postponements left taxpayers ‘off the hook’ completely as the Greek tax office (AADE) considers the delays as grace period. The data that was generated in the grace period must still be submitted to the authorities through the myDATA platform by 31 October 2021.

Extension of reduced VAT rate 

Greece has confirmed a further extension of the reduced VAT rate of 13% for cinemas, drinks and catering services, public transport and packaged holidays until 31 October 2021.

Greece MyData: delayed again

Greece’s e-Invoicing and e-Books mandate, which was supposed to have started on January 1, 2020, has been delayed again. Under pressure of the COVID 19 economic impacts and following requests from the business community, Greece’s AADE has decided to postpone the compulsory usage of the MyData e-Invoicing and e-Books platform until April 2021. Also, the platform is still undergoing development. We are currently analysing the impact of this delay as companies can still voluntarily submit transactional data to the platform.

Greece delay Oct 1st invoice registration mandate

The Greek Government did an about turn on Oct 1st, the day of the mandate, to extend the voluntary period for invoice registration to January 1st 2021 citing economic impact of COVID and business readiness.

Greece announce e-invoicing plans to improve their national VAT gap

In a bid to fight indirect tax evasion, the Greek government is adopting an invoice clearance model that is similar to Mexico’s current setup.

Greece to mandate B2B e-invoicing

The Independent Authority of Public Revenue (Α.Α.Δ.Ε.) announced its intention in introduce mandatory e-invoicing and e-maintenance of accounting books as of 1 January 2020.