On October 31, 2019, the Executive Branch issued Decree 2787/2019 (the Decree) establishing the schedule of the effective dates and the effectiveness of the provisions contained in Law 6380/2019 (the Law/Reform).

In view of the foregoing, the Reform will be effective and will impact the taxes according to the following schedule:

1. For the Corporate Income Tax (IRE), it will have the following cuts:

a. The Reform will become effective on January 1, 2020 for those companies whose next fiscal year-end is December 31, 2019.

b. The Reform will become effective on May 1, 2020 for those companies whose next fiscal year-end is April 30, 2020.

c. The Reform will become effective on July 1, 2020 for those companies whose next fiscal year-end is June 30, 2020.

2. Regarding the Special Valuation Standards for Transactions: The Reform will become effective on January 1, 2021.

3. Regarding Dividends and Profits Tax (IDU): The Reform will be effective as of January 1, 2020.

4. Regarding Personal Income Tax (IRP): The Reform will be effective as of January 1, 2020.

5. Regarding the Non-Resident Income Tax (INR): The Reform will be effective as of January 1, 2020.

6. Regarding Value Added Tax (VAT): The Reform will become effective as of January 1, 2020.

7. Regarding the Selective Consumption Tax (ISC): The Reform will become effective as of January 1, 2020.

8. With respect to the General Provisions: Except for articles 144, 145, 149, 151 and 152, the Reform will become effective as of January 1, 2020.

On the other hand, the provisions related to the Income Tax on Commercial, Industrial or Service Activities and the Income Tax on Agricultural Activities will remain in force until April 30 and June 30, 2020, so that taxpayers who have their tax closings on such dates may comply with their tax obligations in an orderly manner.

Likewise, the system of Advances and Withholdings affecting the payment of the IRE, provided for in Article 24 of Law 6380/19, will not enter into force until January 1, 2023.

Article 3 of the Decree establishes that the Electronic Invoice will come into force once the State Secretariat of Taxation (SET) has regulated the Integrated Electronic Invoicing System (SIFEN).

Finally, the Decree authorizes SET to take the necessary measures for the correct application of the Law.

We believe that the Decree is in line with the spirit of the Law; on the one hand, it seeks that the regulation of the same be carried out as expeditiously as possible, and on the other hand, that the introduction of the reforms be carried out in a gradual, orderly and staggered manner in order to allow the best possible adaptation by the subjects affected by the Reform.