Greece: Digital Reporting and e-invoicing Requirements in Greece

1.     B2B and B2C Transactions

The Greek Ministry of Finance and the Independent Authority of Public Revenue (IAPR) have introduced myDATA (my Digital Accounting and Tax Application) in 2020. This is an electronic platform functioning as an extensive e-reporting system.

Under the current Greek tax legislation, all companies and entrepreneurs established in Greece are subject to the Greek Accounting Standards legislation and obliged to transmit their accounting data to MyDATA. The transmission is structured based on the specifications and configurations provided by the IAPR. All invoices issued or received should be first categorized according to the categories provided by the IAPR and then uploaded in the electronic platform.

There are several channels taxpayers may use in order to submit their issued invoices for either B2B or B2C transactions:

• ERP,
• Authorized Electronic Invoicing Service Provider, 
• Special transmission form (for a very small number of invoices),
• Invoicing application accessible through the website of the IAPR,
• Electronic tax mechanisms for retail transactions

Additionally, the taxpayers are obliged to transmit data of the goods and services received when there is no such obligation from the issuer of the invoice (e.g. intracommunity acquisitions, imports, services received from non-established in Greece suppliers, other organizations exempted etc.) and to transmit the accounting entries as well (e.g. payroll, depreciation, accruals etc.).  

Based on this reporting, the IAPR maintains a database with the transmitted data, which constitutes the electronic books of each company and entrepreneur. These data enables the IAPR to prepare the VAT return of every taxpayer. The taxpayer is responsible for the reconciliation of the transmitted data with its accounting books as well as for modifying the relevant VAT return accordingly in case the uploaded invoices have been rejected by the system. Currently, the data of such a return can be modified by the taxpayers in case there are discrepancies between the accounting books and the VAT return prepared by the system. However, the IAPR has announced that in the near future the prepared VAT return will not be modifiable. 

The IAPR aims in the near future to determine the accounting and tax result of each company and entrepreneur and their liabilities to pay VAT or other taxes (withholding, stamp duty etc.).

Recent developments in the tax legislation for this digital reporting system include as of 01.01.2024 the following:

• The online/real time transmission of invoices and other documents issued by the companies and entrepreneurs.
• The invoices issued should be marked with a two-dimensional matrix (QR code) which includes a link for direct access to the digital service of the digital platform myDATA for the immediate overview of the invoice’s details in a web browser. The link is received upon successful transmission of the document to the myDATA digital platform and is used by business ERP to generate the QR code (URL type), through which the document can be reviewed.  
• The value of revenues subject to VAT as declared on the VAT Return cannot be lower than those which have been electronically transmitted/uploaded to the IAPR via myDATA platform. Respectively, the value of the expenses subject to VAT as declared in the VAT Return cannot exceed the ones that have electronically transmitted/uploaded to IAPR via myDATA platform.
• The tax deductions and expenses for tax relief are not taken into consideration if the supporting documents have not been electronically transmitted to the IAPR.
• Shipping documents should also be transmitted to the myDATA platform. However, instructions for the implementation of this obligation are expected from the IAPR in the near future.
• Retail transactions (B2C) data issued via electronic tax mechanisms should be also transmitted online to the myDATA platform.
• In cases where the issuer of the invoice does not transmit his revenues to the MyDATA platform or transmitted with less value (deviation), the recipient of the invoice should declare it and the issuer will face penalties. The referred transmission is limited to the deadline for submitting the VAT.
• It is important to note that although the above had already been published in the Government Gazette, along with the penalties which will be imposed in case a company fails to comply with its MyData obligations, there are cases where the law provides the issuance of additional Ministerial Decisions for their implementation. 

2.     B2G Transactions

On the other hand, the Greek Ministry of Finance has adopted mandatory e-invoicing for contracts between taxpayers and the Public Sector (B2G).

The e-invoicing context/structure is based on the European standards for issuing electronic invoices and aims to facilitate the public procurement process, reduce administrative burdens, create transparent relations between the taxpayers and the public sector, reduce paper-based invoice and minimize invoicing errors.   

The obligation is applied gradually depending on the public administration the invoice is issued to and the legal framework governing the relevant contracts.

The obligation started on 12 September 2023 and will be completed in January 2025, with the mandate to issue e-invoices to all the general state administrative bodies.

The condition for applying the mandatory e-invoicing is not the date of the relevant invoice issuance but the date the process of the contract’s decision commences.

E-invoicing on B2G transactions may be performed only through a certified e-Invoicing service provider which has additional licensing requirements. The e-invoicing service provider has the same obligations for the online transmission of the documents issued to the myDATA platform.