Greece Establishes Legal Basis for myDATA Scheme and Introduces New E-Invoice Requirements

Joanna Hysi
December 10, 2019

First legislation of the myDATA

The requirement for the mandatory submission of tax data to the Independent Authority for Public Revenue (IAPR) has finally been established in law, specifically in the new tax bill approved by the Greek parliament just a few days ago. The tax bill further mandates the IAPR to finalize, by way of secondary law or decision, the myDATA framework, i.e. the technical specifications, the scope, any exemptions and any other necessary information about the myDATA system.

As a result, the IAPR recently announced that the implementation of the myDATA framework will be postponed until 1 April 2020. Although this date is still to be formally communicated by the Greek authorities, this postponement has been informally communicated and circulated by the Greek press.

New e-invoicing requirements

The tax bill further introduces two new e-invoicing requirements:

  1. It mandates the competent authorities to adopt secondary legislation to define the e-invoice format exchanged between the parties in B2B transactions following the European Norm, as defined in the Directive 2014/55/EU.
  2. It assigns certain e-invoicing service providers, potentially of an “accredited” function – an important role in the e-invoice issuance process, i.e. to guarantee integrity and authenticity of the e-invoice. By virtue of this law, a new method for e-invoice issuance via these “accredited” service providers is now included in the open list of methods of ensuring integrity and authenticity of the e-invoice. The law mandates the competent authorities to regulate in detail, by virtue of a secondary law or decision, the special scheme for this category of e-invoicing service providers.

What is to come?

The goal of the IAPR is to implement e-invoice clearance alongside the myDATA scheme. However, at this stage it seems that such an implementation would initially remain voluntary for taxable persons, since Greece, just like Italy, first must seek an EU derogation from certain provisions in the EU VAT Directive.

It’s worth remembering that Italy’s circumstances were different to why Greece is seeking a derogation, among the most important is the lack of an existing e-invoicing infrastructure in Greece that could ease the transition to a full nationwide e-invoicing mandate. With this in mind, an April go-live date for the e-invoicing leg of the mandate, even on a voluntary basis, remains a rather ambitious initiative from the Greek authorities.


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Joanna Hysi

Joanna is a Senior Regulatory Counsel at Sovos. Based in Stockholm and originally from Greece, Joanna’s background is in commercial and corporate law with research focus on EU law and financial innovation. Joanna earned her degree in Law in Greece and her masters in Commercial and Corporate from London School of Economics and Political Science (LSE) in London.
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