Transfer pricing Greece and other amendments to the Greek tax legal framework

The Greek government is to introduce several changes to the tax framework. This includes, for example, relief from double taxation for intercompany transactions subject to transfer pricing rules or the enforcement of stamp duty obligation. The Ecovis experts explain the details of the tax changes.

Transfer pricing

In an effort to justify and modernise its tax system, Greece has adopted a new method when assessing corporate taxes resulting from intercompany transactions. In a more analytical approach, where profits are adjusted due to intragroup transactions that have been subject to tax in Greece, the associated party will be entitled to submit an amended tax return within a period of three months to adjust and reduce its taxable profits accordingly.

Reinforcement of the stamp duty obligation

The stamp duty obligation for funding Greek Corporations with debt has been reinforced retroactively as of 1 January 2021. Law 4972/22, recently passed by the Greek parliament, adopts the old practice applied by the Greek tax authorities where deals containing interest loan agreements, cash facilitations and other modern cash management practices such as cash pooling etc. should be subject to stamp loan burden under certain conditions.

The new legislation is expected to increase uncertainty regarding the stamp duty obligation on loans concluded before 1 January 2021 and transferred or repaid after the enforcement of the new law.

We offer local and international companies comprehensive advice on all aspects of taxation.

Dimitrios Leventakis, Partner, Certified Tax Advisor, ECOVIS HELLAS L.T.D, Athens, Greece

Paying stamp duty on time

Corporations should carefully examine whether they have concluded interest bearing loans or other financial transactions covered by the new provisions in order to secure timely payment of stamp duty by 31 December 2022.

Transmission of retail receipts to the “myData” digital platform

The new legislation also introduces some penalties for the non-transmission of retail receipts to the government’s digital platform “myData”, depending on whether or not the receipts are subject to VAT.

For further information please contact:

Dimitrios Leventakis, Partner, Certified Tax Advisor, ECOVIS HELLAS L.T.D, Athens, Greece
Email: dimitrios.leventakis@ecovis.com