The Greek Public Revenue Authority (AADE) has published Circular E. 2018 of 23 February 2022, which provides guidance on the application of the Greek CFC rules as introduced from 1 January 2019 in line with the EU Anti-Tax Avoidance Directive and BEPS Action 3.
One important aspect of the guidance concerns the type of taxpayers that are not subject to the CFC rules, which includes shipping companies operating under the Greek tonnage tax regime. Further, it is provided that the exemption fro…