|Dryllerakis & Associates|
|Zepos & Yannopoulos, Taxand Greece|
Since the financial crisis of 2008 the biggest issue in Greece has been the country's sovereign debt and the subsequent repayments of the bailout package agreed with the EU. Tax reform has been prioritised in an attempt to rid the system of corruption and inefficiency as Greece seeks to get its public finances in order.
"There are reforms taking place in Greece, but in my opinion they are not in the right direction, they increase bureaucracy and increase the amount of obligations on the taxpayers. I do not think they will have the desired effect," said Martha Papasotiriou, tax lawyer at UnityFour in Greece.
In October 2015, the law on penalties for late submission of tax returns and TP documentation was changed in an attempt to rationalise the system. This introduced an increasing penalty for the longer documentation is left inaccurate or late. Repeated failure to file proper TP documentation year on year can lead to significantly higher penalties.
Greece has committed to engage in the sharing of information between relevant tax authorities, but has not yet moved to introduce country-by-country reporting (CbCR). On January 27 2016 the General Secretary of Public Revenues signed the multilateral competent authority agreement for the automatic exchange of CbCR.
A lack of sophistication when it comes to transfer pricing is something that advisers blame for a sometimes frustrating experience when dealing with the tax authorities. "I do not think they have a full and thorough knowledge of the transfer pricing methods – not all the auditors. They don't always have the experience to audit large firms, so this can make it difficult," said Papasotiriou.
The General Secretariat of Public Revenues also this year issued a new ministerial circular on June 6 relating to the application of transfer pricing documentation rules in cases of mergers by absorption relating to the Greek law on business restructuring.
This provision requires that until the date of completion of the restructuring, the absorbed company is liable for TP documentation to verify all transactions for itself and its associated enterprises are at arm's-length.
(As of April 2016)
|Corporate income tax||29%|
|Capital gains tax||29%|
|Bank interest||15% (b)(c)|
|Interest on treasury bills and corporate bonds||15% (b)(c)|
|Repos and reverse repos||15% (b)(c)|
|Paid to Greek legal entities||15%|
|Paid to Foreign legal entities||15% (c)(d)|
|Technical service fees, management service fees, consulting service fees and fees for similar services||20% (f)|
Net operating losses (years)
Source: EY 2016 Worldwide Corporate Tax Guide