Market overview

Greece is still feeling the effects of the 2008 economic crisis. The tax authorities are focusing on enhancing transparency and there have been many progressive, albeit slow steps made by the government to align domestic law with the OECD's BEPS provisions.

Greece is a signatory of the multilateral agreement (MLI) regarding country-by-country reporting (CbCR).

The country has taken steps to implement this and, in July 2017, proposed legislation concerning CbCR-specific requirements. The draft law would modify the Greek Corporate Income Tax law to include documentation requirements. The law proposes penalties of €10,000 ($12,000) for non-submission of CbCR and €5,000 for late or inaccurate submissions.

"With this theme in mind, the Greek authorities are becoming more sophisticated," said Daphne Conzonis, partner at Zepos & Yannopoulos, Taxand Greece. "This is generating more conversation and more litigation."

In July 2016, the Greek parliament approved a bill put forward by the Ministry of Finance, introducing changes to TP documentation requirements.

A major feature of this bill was the extension of the TP documentation files and summary information sheets to coincide with the deadline for annual corporate income tax returns. The amended deadline covers documentation prepared from January 2015 onwards.

This legislation provides simplified documentation requirements for small entities and exemptions for very small entities.

Another feature of the bill was the extension of the deadline for providing decisions on advance pricing agreements (APAs) to 18 months (it was previously 120 days), from the date the APA request is submitted. If permission is granted, the APA can be extended up to 36 months.

The overall impact of this bill is a more practical timeframe for taxpayers.

"There is a new disclosure programme, which is very much linked with enhanced disclosure," said George Naskaris, head of tax at Koutalidis Law Firm. "There were a lot of people asking how to regularise their affairs, particularly due to the very aggressive tax authorities in view of the financial crisis."

In June 2017, the Greek government extended the deadline for a voluntary disclosure programme by four months until the end of September 2017. The programme is advantageous for those who had not fully declared foreign income and gains, such as the local hires of Greek subsidiaries of multinational companies that had not declared dividends on shares held in a multinational company.

Tax authorities

Hellenic Republic Ministry of Finance
Victory 5-7, 105 63 Athens
Tel: +30 210 333 2000
Fax: +30 210 333 2608

Tax rates at a glance

(As of July 2017)

Corporate income tax 29%
Capital gains tax 29%
Branch tax 29%
Withholding tax
Dividends 15% (a)
Bank interest 15% (b)(c)
Interest on treasury bills and corporate bonds 15% (b)(c)
Repos and reverse repos 15% (b)(c)
Other interest
Paid to Greek legal entities 15%
Paid to Foreign legal entities 15% (c)(d)
Royalties 20% (c)(d)
Technical service fees, management service fees, consulting service fees and fees for similar services 20% (f)
Net operating losses (years)
Carryback 0
Carryforward 5

  1. The 10% withholding tax rate applies to dividends and interim dividends distributed by a Greek corporation (anonymos eteria, or AE; (in certain countries, a corporation is referred to as a société anonyme, or SA) and profits distributed by a Greek limited liability company (eteria periorismenis efthinis, or EPE). This 10% withholding tax is subject to rates applicable under double tax treaties or under the European Union (EU) Parent-Subsidiary Directive (amended by Directive 2011/96/EC).
  2. This 15% withholding tax is subject to rates applicable under double tax treaties or under the EU Interest-Royalties Directive.
  3. This is a final tax if the beneficiary is a legal person (for example, a company) or legal entity that satisfies both of the following conditions:
    • It does not have its tax residency in Greece.
    • It does not maintain a permanent establishment for corporate income tax purposes in Greece.
  4. This 20% withholding tax is subject to rates applicable under double tax treaties or under the EU Interest-Royalties Directive. No tax is withheld on payments of royalties made to legal persons or legal entities that have their tax residence in Greece or that have a Greek permanent establishment in Greece.
  5. If the 20% withholding tax does not exhaust the final Greek corporate income tax liability of the beneficiary, it is credited against the beneficiary's final Greek corporate income tax liability.

Source: EY and PwC