Practice area

World TP Reviews

Transfer pricing

Deloitte’s transfer pricing team has 20 fee earners. Because of the BEPS directive, many multinational groups have undergone restructuring and Deloitte is expanding its service offering dedicated to a post-BEPS environment. This includes a diagnostic review regarding post-transfer pricing restructuring, as well as APAs and MAPs.

The transfer pricing team advised on a global documentation project on the biggest ever transaction ever undertaken by the Deloitte Greece tax department, with transactions valued at $1.5 billion. This was the client’s biggest project launched on a global basis.

Deloitte also assisted a major Greek banking group on producing a Country-by-Country Report (CBCR). With a transaction value of $3 billion, Deloitte’s transfer pricing and technology team worked closely together to produce a solution that automated the CBCR compilation process.

Dryllerakis & Associates

Dryllerakis & Associates’ tax team, led by senior partner Sophia Grigoriadou, offers clients comprehensive tax legal advice in key tax areas such as tax controversy, indirect, transaction, transfer pricing, tax planning, and provides tax advisory for criminal law and accounting law. The firm's litigators are experienced in representing clients in both administrative courts and the Supreme Court.

The firm has strengthened its transfer pricing practice with the hiring of Katerina Kalaitzaki, a transfer pricing specialist, who alongside Grigoriadou, assisted Ecolab Greece in preparing a local transfer pricing report. The firm’s role was to describe the transfer pricing policy enacted in the intragroup transactions of Ecolab and to document the arm’s length nature of the transactions consistent with the Greek legislation.


EY has one the largest transfer pricing teams in Greece with 32 fee earners. The firm is active and dominant in sectors such as insurance, pharmaceuticals, healthcare, travel, telecommunications, media and entertainment. Transfer pricing documentation services is its core business. However, the firm also offers APA controversy services such as administrative assistance, judicial procedural developments with the court, technical assistant providing filing documents and appeals against APA assessments defending its clients’ APA strategy from pre-ruling to post-ruling.

EY Greece reviewed a global firm active in the consumer goods sector on its manufacturing pricing policy following the restructuring of the firm’s manufacturing plants. The aim was to find a way to optimise its pricing policy. In order to get an insight into the market practices, the team utilised its international network in 15 countries to conduct a pricing policy survey of similar manufacturers. The findings from the survey were used alongside a transfer pricing benchmark study, comparing similar activities to determine the optimum pricing policy.


UnityFour, an independent firm specialising in tax and accounting, offers a comprehensive tax service. All the senior members have previously worked for the big four. Managing partner Nikolaos Siakantaris has experience in corporate tax, private client, international tax planning and VAT spaces. Martha Papasotiriou – who heads the firm's tax advisory, international tax and transfer pricing services – has broad experience in cross-border structuring, tax consulting, tax planning and transfer pricing.

UnityFour’s Martha Papasotiriou led the transfer pricing team on advising a technology group on a detailed transfer pricing strategy that meets the requirements of Greek legislation. The team then moved on to preparing the transfer pricing file for the Greek associated firms. Its transactions were valued at €5 million.

Siakantaris and Papasotiriou provided transfer pricing advice to a Greek group with subsidiaries in more than 55 countries worldwide. UnityFour developed a detailed transfer pricing strategy consistent with the Greek legislation and prepared transfer pricing documentation for the Greek subsidiaries from the beginning since additional transactions to be documented.

Zepos & Yannopoulos

Elina Fillipou, recently promoted to partner in 2018, leads the Zepos & Yannopoulos tax team. The transfer pricing team has five members, two lawyers and three economists (two from big four firms). It offers a wide range of transfer pricing services, such as design of transfer pricing strategy and economic analysis of transactions, APAs, dispute resolution and more. In addition, the law firm also has the expertise and capability to advise and prepare transfer pricing documentation. Cross-border reorganisations of Greek operations is an area that the firm has gained comprehensive experience.

Fillipou assisted a client in designing and implementing the transfer pricing policy of a Greece-domiciled multinational group. It included assisting the client to align its transfer pricing policy regarding intangible assets, prepare relevant documentation and assist the client with reporting obligations.

Client feedback

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