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
