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 co…