The Greek Public Revenue Authority has issued a circular on the rules introduced by Law 4446/2016 ({News-2016-12-27/A/3-previous coverage}) for the taxation of capitalized or distributed accounting profits not previously subject to tax. The circular clarifies that as of 2017, such un-taxed profits will be taxed on a grossed-up basis as profits from business activity when capitalized or distributed, regardless of the existence of any tax losses. For the avoidance of double taxation, the gross…