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This article provides an in-depth overview of the Greek corporate tax framework as it stands in 2026, integrating recent legislative reforms, EU directives and OECD-driven developments. It is intended as professional commentary for in-house counsel, CFOs, investors and foreign advisers seeking a structured view of doing business in Greece. It does not constitute legal advice; for matters concerning a specific transaction or structure, please contact our firm directly.

1. Introduction: The Greek Tax Environment in 2026

Greece’s corporate tax system has undergone a decade of structural transformation. The combined pressures of EU harmonisation, the OECD Base Erosion and Profit Shifting (BEPS) project, and the country’s post-crisis pursuit of foreign direct investment have produced a legal framework that is, today, broadly predictable, treaty-based and aligned with international norms — while retaining a distinct national character through targeted incentives in shipping, innovation, strategic investment and, more recently, defence.

For clients of Tsamichas Law Firm, the practical question is no longer whether Greece is a competitive jurisdiction — it demonstrably is — but how to navigate its increasingly layered architecture of ordinary rules, sectoral regimes, anti-abuse provisions and minimum-tax obligations. This guide sets out the essentials.

2. Corporate Vehicles and Their Tax Classification

2.1 The spectrum of business forms

Greek law recognises several corporate forms, of which three dominate commercial practice:

• the société anonyme (Ανώνυμη Εταιρεία, AE), the classic joint-stock company, subject to a minimum share capital of EUR 25,000;
• the private company (Ιδιωτική Κεφαλαιουχική Εταιρεία, IKE), a flexible, modern vehicle widely used by SMEs and start-ups; and
• the limited liability company (Εταιρεία Περιορισμένης Ευθύνης, EPE), now largely superseded in practice by the IKE.

These three are capital companies: their members enjoy limited liability. General partnerships (OE) and limited partnerships (EE) remain common among family businesses and service providers. Civil partnerships, consortiums and other specialised vehicles complete the landscape.

Tax classification. Corporations and partnerships alike are treated as separate taxable persons. Greek law does not, as a rule, recognise tax transparency for commercial entities.

2.2 Exceptions: tax-transparent and specially taxed vehicles

A narrow set of investment vehicles benefits from either transparent or flat, asset-based taxation:

• Venture capital mutual funds (AKES) and alternative investment funds (OEE) may elect fiscal transparency, or opt for annual taxation calculated on the net appreciation of their portfolio, with that tax discharging all further income tax obligations of the fund and its unitholders.
• UCITS (OSEKA) are taxed at a percentage of their net assets; the levy exhausts the tax liability of both the fund and its shareholders.
• Real estate investment companies (AEEAP) are taxed at a percentage of the average fair market value of their investment portfolio, with the same exhaustive effect. They are therefore outside the ordinary corporate income tax base — a feature that has made them the vehicle of choice for large-scale pooled real estate investment in Greece.

2.3 Residence: where is a company “Greek”?

Subject to applicable tax treaties, a company is a Greek tax resident if any of the following is satisfied:

1. it is incorporated under Greek law;
2. its registered seat is in Greece; or
3. its place of effective management is in Greece.

The third limb is fact-sensitive and the most frequently litigated. Greek authorities examine where day-to-day business is conducted, where strategic decisions are taken, where board and shareholder meetings occur, where books and records are kept, and where directors reside. In marginal cases, the residence of the majority shareholders may also be weighed. Specialised regimes — notably for shipping — displace these rules.

3. Corporate Tax Rates and the Taxable Base

3.1 Headline rates

The standard corporate income tax rate in Greece is 22%. This rate applies to AEs, IKEs, EPEs, general and limited partnerships, and most other legal persons or entities that keep double-entry books.

The principal exception concerns credit institutions that have elected to apply the regime converting deferred tax assets into deferred tax credits against the Greek State for capital-adequacy purposes; these institutions are taxed at 29%.

Individuals carrying on business activities are taxed on a progressive scale of 9% to 44%, with business income aggregated with employment and pension income. Individuals transferring their tax residence to Greece under special incentive regimes (notably the non-dom, pensioner and repatriation regimes) may qualify for reduced or flat taxation for up to seven years.

3.2 Advance payment of tax

Greek companies must prepay a portion of their annual corporate tax:

• 80% for most legal persons;
• 100% for banks and bank branches;
• 55% for business income earned by individuals.

For newly formed legal persons and banks, the prepayment is halved during the first three years of operation; for individuals, the 50% reduction applies only in year one.

3.3 Computing taxable profit

Taxable profit is calculated on the basis of accounting profit, adjusted for items specifically addressed by the Income Tax Code. Deductible items include:

• ordinary business expenses that have been (i) actually incurred, (ii) incurred in the business interest, and (iii) properly recorded and documented;
• depreciation at statutory rates;
• limited bad-debt provisions.

Since fiscal year 2023, individuals carrying on business are subject to a minimum imputed profit calculated by reference to a statutory formula.

3.4 Non-deductible items: the usual suspects

The legislation enumerates items that may not be deducted, including:

• provisions (save for specific bad-debt provisions);
• administrative and criminal fines and penalties;
• payments for goods or services exceeding EUR 500 not effected through banking channels;
• unpaid social security contributions;
• payments to recipients resident in jurisdictions designated as non-cooperative or (outside the EU/EEA) preferential, unless the taxpayer evidences genuine economic substance;
• expenses whose supporting documentation has not been transmitted through the myDATA platform of the Independent Authority for Public Revenue (AADE).

Profits that have not been taxed at the corporate level — for example, under a specific exemption — become taxable upon their distribution or capitalisation.

4. Investment Incentives and Special Regimes

Greece deploys an increasingly sophisticated incentive toolkit. At Tsamichas Law Firm, we structure around these regimes routinely; the summary below captures the most commercially relevant categories.

4.1 Research, development and innovation

Qualifying R&D expenses, including depreciation of dedicated equipment, benefit from an additional 100% super-deduction in the year they are incurred, subject to a governmental procedure. Enhanced rates apply where the expenditure is directed to non-affiliated registered start-ups and specified research institutions:

• +150% additional deduction for such third-party R&D;
• +200% for micro, small and medium-sized enterprises, provided that the expense exceeds 20% of total annual expenditure;
• +215% where the annual R&D spend exceeds the two-year moving average.

Certain research-dedicated equipment may be depreciated at an accelerated 40% annual rate.

4.2 Patent box

Profits derived from the commercial exploitation of internationally recognised, self-created patents — whether through the sale of patent-embedded products or the provision of patent-enabled services — are fully exempt from corporate income tax for three years from first commercialisation, followed by a 10% exemption for the next seven years. The exempted profits crystallise for tax purposes upon distribution or capitalisation.

4.3 Green incentives and sustainability

Enhanced deductions and accelerated depreciation are available for environmental protection measures, including zero- or low-emission vehicles and employer-provided public transportation passes. Expenses linked to corporate social responsibility (CSR) are explicitly deductible, consolidating a position that had previously been debated in practice.

4.4 Audio-visual production and game development

EU-compatible incentives provide a 30% deduction of eligible expenses incurred in Greece for the production of films, video and television content, ancillary services and video-game source code development. The regime extends to Greek-established producers, foreign producers operating through a Greek branch, and foreign producers contracting with a Greek production vehicle.

4.5 Employment

A 50% super-deduction of employer social security contributions is available in respect of qualifying new full-time hires, subject to statutory caps.

4.6 Business parks

Entities acquiring immovable property and commencing operations in designated industrial areas and enterprise parksbenefit from specific reliefs, notably exemption from real estate transfer tax.

4.7 The shipping regime: tonnage tax

Greek shipping has long enjoyed a distinctive constitutional and tax framework. Under the tonnage tax regime:

• ship-owning companies, bareboat charterers and ship lessees pay a tax calculated on the capacity and age of the vessels;
• this tax discharges the entire income tax liability of the operating company and of its shareholders, to the extent the income derives from the operation and exploitation of the vessels;
• foreign-flagged vessels fall within the regime only if managed in Greece by foreign companies operating through a Greek office under the special statutory framework, or by Greek-resident companies; vessels flying EU/EEA flagsmay qualify regardless of management location, for defined vessel categories.

Shipping-adjacent activities (brokering in chartering, sale and purchase and newbuilding of vessels exceeding 500 gross registered tons) carried out in Greece are subject to an annual contribution calculated on the amount of foreign currency that must, by law, be imported annually to cover operating expenses.

4.8 Shared services under Law 89/1967

The Law 89/1967 regime is a cost-plus framework for shared-services centres established in Greece to serve affiliated companies. Eligible services include marketing, consulting, IT support, software development, data management and call-centre operations. Key features:

• expenses are fully deductible;
• taxable income equals the gross revenue from related parties, computed as costs plus a mark-up of at least 5%, agreed in advance with the tax authorities;
• minimum operational footprint: annual expenditure of at least EUR 100,000 and employment of four persons (one of whom may be part-time).

4.9 State aid and strategic investments

Greece’s private investment aid framework focuses on thirteen defined sectors, with an emphasis on green transition and advanced technologies. Tax exemptions constitute one of the principal forms of aid granted.

The strategic investments framework, modernised in 2019 and enhanced in 2021, has been further expanded to cover Emblematic Investments of Exceptional Importance. The scope now embraces:

• renewables, green hydrogen, offshore wind and floating photovoltaic projects;
• critical raw materials and circular-economy initiatives;
• shipbuilding and allied industries;
• projects anchoring Greece in globally competitive supply chains.

Depending on the investment category, incentives may include:

• stabilisation of the applicable tax rate for 12 years;
• deferred corporate income tax;
• accelerated depreciation;
• favourable personal taxation for expatriate executives; and
• tax exemptions usable over a period of up to 15 years.

4.10 Defence: the new super-deduction regime

Article 13 of Law 5246/2025 introduced a 100% super-deduction for qualifying capital expenditure in defence-related and allied manufacturing facilities. Eligibility is open to all enterprises with a registered seat or branch in Greece, provided:

• the initial investment is realised in 2026, 2027 or 2028; and
• the project is maintained in an eligible region for at least five years from completion.

Non-compliance triggers revocation of the benefit and repayment of the super-deducted amount. The regime is designed to operate within Commission Regulation (EU) 651/2014 and the General Block Exemption Regulation (GBER).

4.11 Stock-exchange listing for SMEs

Under Article 24 of Law 5193/2025, micro, small and medium-sized enterprises are entitled to an additional 100% deduction of costs incurred in connection with listing on a regulated market, capped at EUR 200,000 of tax benefit. Qualifying expenses include due-diligence fees, advisory and co-ordination fees, statutory charges, prospectus preparation and related documentation. The listed securities must remain on the regulated market for at least ten consecutive years; early delisting may trigger wholesale or partial reversal of the benefit. The regime applies to expenses incurred in tax years 2025, 2026 and 2027.

5. Losses, Interest and Capital Gains

5.1 Loss utilisation

Tax losses may be carried forward for five fiscal years to be set off against future profits. Greece does not permit loss carry-back and does not operate a consolidated tax group regime. Foreign losses are, as a rule, not usable in Greece; a narrow exception applies to losses of EU/EEA permanent establishments where the relevant profits are not otherwise exempt under a treaty.

Losses are forfeited where, within a single fiscal year, direct or indirect participation in the company’s capital or voting rights changes by more than 33% and, within the same or the following year, the company changes its business activity in a manner that affects more than 50% of its turnover. The forfeiture does not apply where the activity change is economically justified — for example, by cost-cutting, achieving economies of scale or intra-group restructuring.

5.2 The interest limitation rule

Transposing Article 4 of the EU Anti-Tax Avoidance Directive (ATAD), Greece caps the deductibility of exceeding borrowing costs at 30% of tax EBITDA, subject to a EUR 3 million de minimis threshold. Exceeding borrowing costs are defined as deductible borrowing costs minus taxable interest and economically equivalent income. The non-deductible excess is carried forward without time limitation.

Group-ratio relief is available for companies belonging to a consolidated group under Greek GAAP: they may deduct all exceeding borrowing costs where their equity-to-assets ratio is within two percentage points of the group ratio, and may alternatively deduct up to the amount derived from applying the group’s third-party exceeding borrowing costs ratio to their own EBITDA.

Financial undertakings — credit institutions, insurance companies, institutions for occupational retirement and similar — are carved out. Transfer pricing adjustments are made before applying the interest limitation.

A separate cap applies to non-bank intercompany interest rates: the portion of interest corresponding to any rate exceeding the Bank of Greece’s published rate for credit lines to non-financial corporations is not deductible. Bank loans, bond loans and arm’s-length-compliant related-party loans are excluded from this cap.

5.3 Capital gains and the participation exemption

Capital gains realised by a corporation — including on the disposal of shares — are fully taxable in the year of realisation, save where a specific exemption applies.

The Greek participation exemption has been significantly expanded. It applies to both:

• Greek legal persons, and
• Greek permanent establishments of non-resident EU/EEA legal persons,

and exempts capital gains on the disposal of shares in qualifying subsidiaries, provided that a minimum 10% participation has been held for at least 24 months.

For fiscal years beginning on or after 2025, the exemption has been extended to capital gains from the disposal of shares in non-EU qualifying subsidiaries, aligning Greece with the broader European trend.

A transitional regime permits deduction of capital losses on share disposals incurred between 1 January 2020 (for EU subsidiaries) or 1 January 2025 (for non-EU subsidiaries) and 31 December 2026, subject to the losses being reflected in audited financial statements and recorded in the taxpayer’s books.

5.4 Tax-neutral reorganisations under Law 5162/2024

Law 5162/2024 has unified the framework for tax-neutral corporate reorganisations, superseding the overlapping regimes of Laws 1297/1972, 2166/1993 and Articles 52–56 of Law 4172/2013. Under the new law, capital gains arising on mergers, divisions, partial divisions, asset contributions and share-for-share exchanges are, subject to specific anti-abuse rules, exempt from tax at the moment of the transaction, with roll-over into the resulting entity’s tax attributes.

The law offers long-awaited legislative coherence. Counsel advising on Greek M&A and intra-group restructurings must now reason from a single statutory text rather than a patchwork of overlapping regimes.

6. Indirect and Transaction Taxes

6.1 Value added tax (VAT)

The standard VAT rate is 24%. Reduced rates apply to specific supplies — hotel accommodation, certain foodstuffs, social services, and others. VAT is a pass-through cost for fully taxable businesses.

6.2 Digital Transaction Duty (from 1 December 2024)

As of 1 December 2024, the Digital Transaction Duty replaced most applications of the former stamp duty. It applies where at least one party is a Greek tax resident (or a foreign person acting through a Greek permanent establishment), provided that the transaction is outside the scope of VAT and specific other taxes such as inheritance and real estate transfer tax.

Headline rates:

• 2.4% on most business-to-business transactions falling within scope, including loans and credit facilities up to EUR 150,000 per loan;
• 3.6% on commercial leases.

The duty does not apply to interest payments, to bond loans governed by Law 4548/2018, or to loans granted by banks.

6.3 Real estate transfer tax and VAT on new buildings

Transfers of immovable property (other than new buildings) bear a 3% real estate transfer tax, calculated on the higher of the contract price and the statutory “objective value”. A 3% municipality surcharge on the tax itself brings the effective rate to 3.09%. Qualifying corporate reorganisations under Law 5162/2024 benefit from reduced rates.

Sales of new buildings by businesses are, in principle, subject to 24% VAT. A suspension mechanism in force through 2025 permits constructors to elect for VAT-exempt treatment on sales of buildings completed after 1 January 2006; non-recoverable input VAT in such cases may be deducted as an income tax expense.

6.4 Transfer tax on listed shares

Sales of shares listed on a Greek regulated market or multilateral trading facility bear a 0.1% transfer tax.

6.5 Banking levy (Law 128 contribution)

Greek and foreign credit institutions pay an annual levy on loans and credits, at rates ranging between 0.12% and 0.6%depending on the facility type.

6.6 Capital accumulation tax

Capital contributed to Greek legal entities in the context of a capital increase is subject to a 0.2% capital accumulation tax. No tax is imposed on capital contributed at incorporation. AEs additionally pay a 0.1% duty in favour of the Hellenic Competition Commission.

6.7 Real estate holding taxes

ENFIA (Ενιαίος Φόρος Ιδιοκτησίας Ακινήτων) — the Unified Real Estate Tax — applies to property owners and comprises:

• a main tax calculated per property using statutory coefficients (from EUR 0.0037 to EUR 16.20 per square metre, multiplied by adjustment factors); and
• a supplementary tax at 0.55% on the portfolio value, reduced to 0.1% for properties used in the owner’s business activity.

The Special Real Estate Tax of 15% targets opaque ownership of Greek real estate by non-transparent structures. In practice, wide exemptions apply — notably for listed entities, regulated investment vehicles (recently extended to AIFs under the AIFM Directive), and structures whose ultimate beneficial owners are identified via Greek tax identification numbers.

6.8 Other levies

Municipal duties and property duties, entrepreneur’s duty under Law 3986/2011 (around EUR 1,000 annually for a single registered seat), and assorted third-party levies (for pension funds, universities and similar) round out the annual cost picture.

7. Inbound Investment: Withholding Taxes and Treaty Benefits

7.1 Domestic withholding tax rates

In the absence of treaty relief or EU Directive benefits, the following rates apply to outbound payments to non-residents lacking a Greek permanent establishment:

Withholding typically discharges the non-resident’s Greek tax liability on that income stream.

7.2 Treaty network

Greece maintains income tax treaties with 58 jurisdictions. Investment flows are concentrated in a familiar cluster: Germany, France, Switzerland, Cyprus, Italy, the United States, Luxembourg, the Netherlands and the United Kingdom. Treaty rates commonly reduce or eliminate domestic withholding on dividends, interest and royalties.

The treaties with the United States and the United Kingdom pre-date the OECD Model and retain idiosyncratic features, meriting careful review in cross-border structuring.

7.3 Parent-Subsidiary and Interest-Royalties Directive exemptions

Dividends to qualifying EU parents are exempt from Greek withholding tax where:

• the parent holds at least 10% in the capital or voting rights of the Greek subsidiary for a continuous period of 24 months;
• the parent is listed in Annex I Part A of the Parent-Subsidiary Directive;
• the parent is resident in an EU Member State and not treated as non-EU resident under any third-country treaty; and
• the parent is subject, without election or exemption, to one of the corporate taxes listed in Annex I Part B of the Directive (or a substituted tax).

Until the 24-month holding period is completed, a bank guarantee may be posted in lieu of the withholding tax, with subsequent refund upon compliance with the holding condition.

A dedicated anti-abuse rule denies the exemption where the arrangement lacks valid commercial reasons reflecting economic reality and is principally motivated by the pursuit of tax advantage.

Interest and royalties to qualifying EU associated enterprises are similarly exempt under the Interest and Royalties Directive, subject to a 25% minimum participation for 24 months and the other Directive conditions.

7.4 Listed corporate bonds

Interest payments made on or after 1 January 2020 to non-residents without a Greek PE are exempt from withholding tax where the underlying instrument is a corporate bond listed on an EU trading venue, or on a regulated non-EU market supervised by an IOSCO-accredited authority.

7.5 Treaty shopping and the Principal Purpose Test

Greece ratified the OECD Multilateral Instrument (MLI), which entered into force on 1 July 2021, and has adopted the Principal Purpose Test (PPT). Purely on-paper claims to treaty benefits — without documentary substance, genuine activity or a defensible commercial rationale — are now significantly more exposed. In practice, the tax administration has historically applied the PPT with restraint where a proper tax residence certificate and supporting records are produced, but the trajectory is unmistakably toward closer scrutiny.

8. Transfer Pricing

8.1 Arm’s length principle and documentation

Greek transfer pricing law fully endorses the arm’s length principle as framed by Article 9 of the OECD Model Tax Convention and elaborated in the OECD Transfer Pricing Guidelines, including the post-BEPS Actions 8–10 revisions. Taxpayers are required to maintain master file and local file documentation in accordance with OECD standards.

8.2 Country-by-country reporting

Under Law 4484/2017, multinational groups with consolidated turnover of at least EUR 750 million must file a Country-by-Country Report annually, with automatic exchange across EU Member States.

8.3 Areas of current controversy

Audits increasingly focus on:

• the allocation of DEMPE functions (Development, Enhancement, Maintenance, Protection and Exploitation of intangibles) between domestic licensees and foreign IP holders;
• the reliability of comparables, particularly in intra-group financial transactions;
• the definition of the related-party perimeter;
• the use of full range versus interquartile range, and the appropriateness of comparability adjustments;
• the selection of the tested party and the transfer pricing method; and
• limited-risk distribution arrangements, whose returns the Greek administration routinely tests against functional and risk profiles.

8.4 Compensating adjustments and Mutual Agreement Procedure

Greek law permits compensating adjustments, whether in the original tax return or via an amending return within the five-year statute of limitations. Downward adjustments attract intensified scrutiny.

Where a primary adjustment is made against one Greek related party in connection with a transaction with another Greek related party, the counterparty may request a corresponding adjustment, provided the original adjustment has been paid.

The Mutual Agreement Procedure (MAP) has been the subject of recent procedural upgrades aligning the domestic framework with the MAP Peer Review recommendations. Historical MAP usage for transfer pricing has been limited; practice is still maturing.

8.5 Deductibility of intra-group charges

Payments to affiliates for management and administrative services are deductible only where they satisfy arm’s length standards, serve the payer’s business purpose and are properly documented. Payments to recipients in non-cooperative or preferential jurisdictions (outside the EU/EEA) are non-deductible unless the taxpayer demonstrates genuine economic reality.

9. Outbound Investment: Foreign Income of Greek Corporations

9.1 Worldwide taxation and foreign tax credit

Greek corporations are taxed on their worldwide income. Double taxation is relieved primarily through the foreign tax credit method; the exemption method is available only in limited treaty scenarios for foreign PE profits.

9.2 Dividends from foreign subsidiaries

Dividends received from qualifying EU subsidiaries are exempt under conditions mirroring those applicable to inbound Directive exemptions (see section 7.3 above).

Dividends from qualifying non-EU subsidiaries are, as of fiscal year 2025, also exempt from Greek corporate income tax, provided that:

• the subsidiary is a capital company under its home-country law;
• it is not resident in a non-cooperative jurisdiction;
• it is subject, without election or exemption, to a corporate income tax or similar tax; and
• the Greek parent holds at least 10% of its capital or voting rights for at least 24 months.

The exemption is denied (a) to the extent the underlying distribution is deductible at the subsidiary level — a classic anti-hybrid measure — and (b) where the arrangement falls foul of the dedicated anti-abuse rule mirroring Article 1(2) of the Parent-Subsidiary Directive.

An underlying tax credit remains available for dividends received from jurisdictions whose treaties with Greece provide for it — notably China, Cyprus and the United Kingdom.

9.3 Outbound intangibles and exit taxation

Greek law imposes an exit tax on the market value of assets, net of their tax value, transferred:

• from a Greek head office to a foreign permanent establishment, or
• from a Greek permanent establishment to a foreign head office or another foreign PE,

where the transfer strips Greece of taxing rights. The rule is the direct transposition of Article 5 of the ATAD.

Restructurings involving the transfer of intangibles or of a package of functions, assets, risks and opportunities must be priced at arm’s length; the Greek administration increasingly treats DEMPE attribution as the key analytical lens.

9.4 Controlled Foreign Corporation (CFC) rules

Under Greek CFC rules, the passive profits of a foreign controlled subsidiary (or a foreign PE that is otherwise not taxed in Greece) are imputed to the Greek parent where:

1. the Greek parent, alone or with associated enterprises, holds directly or indirectly more than 50% of the voting rights, capital or profit entitlement of the foreign entity;
2. the actual foreign corporate tax on the entity’s profits is less than 50% of the Greek corporate tax that would have been due; and
3. at least 30% of the entity’s pre-tax income consists of passive categories — interest, royalties, dividends, gains on shares, financial leasing, insurance, banking, and certain intra-group invoicing and low-substance sales and services.

CFC rules do not apply to EEA-resident entities carrying on a substantive economic activity supported by staff, equipment, assets and premises. In such cases, the burden to show the absence of substance rests on the administration.

Previously taxed CFC income is subtracted on subsequent distribution to avoid double taxation.

10. Anti-Avoidance Architecture

10.1 The General Anti-Abuse Rule (GAAR)

Article 38 of the Greek Tax Procedures Code embodies a General Anti-Abuse Rule in line with Article 6 of the ATAD. It permits the tax administration to disregard arrangements — or series of arrangements — that, having been put in place with the principal purpose of obtaining a tax advantage contrary to the object or purpose of the applicable tax law, are not genuine. Non-genuineness is established by reference to whether the arrangement rests on valid commercial reasons reflecting economic reality. The burden of proof lies with the administration; a mere preference for a less-taxed route does not, of itself, constitute avoidance.

10.2 Specific anti-abuse rules

Stand-alone anti-abuse rules apply to:

• the Parent-Subsidiary exemption (both inbound and outbound);
• the Interest-Royalties exemption;
• tax-neutral corporate reorganisations under Law 5162/2024; and
• treaty-shopping arrangements via the Principal Purpose Test under the MLI.

10.3 Hybrid mismatches

The ATAD II anti-hybrid rules, applicable since 1 January 2020, require Greece to deny deductions, tax income or limit tax relief to neutralise:

• mismatches arising from the characterisation of financial instruments, payments or entities;
• hybrid transfers and imported mismatches; and
• mismatches producing double deductions, including those linked to dual residence.

10.4 Mandatory disclosure (DAC6)

Under Law 4714/2020, intermediaries and taxpayers are required to report cross-border arrangements meeting the DAC6 hallmarks. Non-compliance attracts meaningful administrative penalties, and — perhaps more importantly — reputational exposure in tax administrations’ analytical pipelines.

11. Pillar Two and the Global Minimum Tax

11.1 Transposition via Law 5100/2024

Law 5100/2024 transposes Council Directive (EU) 2022/2523 on the Pillar Two global minimum tax into Greek law. The legislation tracks the Directive architecture closely, introducing:

• the Income Inclusion Rule (IIR);
• the Undertaxed Profits Rule (UTPR); and
• a Qualified Domestic Minimum Top-Up Tax (QDMTT), ensuring that Greece collects the top-up tax on low-taxed constituent entities located within its territory.

The target is a 15% minimum effective tax rate for multinational enterprise groups and large-scale domestic groups falling within the Directive’s perimeter.

11.2 Practical implications

For in-scope groups, Pillar Two interacts with Greek incentives in non-trivial ways: headline attractions such as patent-box exemptions, strategic-investment tax rate stabilisations and the 100% defence super-deduction must now be stress-tested against the ETR computation under the GloBE Rules. Structures that once achieved single-digit effective rates in Greece through stacking incentives will, going forward, trigger QDMTT liabilities for covered groups.

11.3 Pillar One

Pillar One has not been transposed in Greece. Adoption awaits finalisation, signature and global entry into force of the OECD Multilateral Convention. When and if it takes effect, Greece — as a predominantly market jurisdiction — is likely to be a net beneficiary of the reallocation of taxing rights.

12. Tax Audits and Statute of Limitations

12.1 The ordinary five-year window

The Greek tax administration’s right to assess additional tax is time-barred five years after the end of the year in which the tax return is due — effectively six years after the audited year.

12.2 Extensions and exceptions

The period extends to ten years where:

• there has been tax evasion;
• the taxpayer has failed to file a return within the five-year window; or
• new information that could not reasonably have been in the administration’s possession within the ordinary period subsequently comes to light.

Where information has been requested from foreign authorities, the limitation period is extended to one year after receipt of the information.

12.3 Audit priorities and risk-based selection

The AADE publishes annually the number of full and partial audits it has prioritised on the basis of risk-analysis criteria. Taxpayers dissatisfied with an assessment must pursue an administrative appeal before the Dispute Resolution Directorate as a prerequisite to judicial review.

13. BEPS, Transparency and the Digital Economy

13.1 Cumulative transposition of BEPS

Greece has, progressively and comprehensively, implemented the BEPS output:

• Action 4 (interest limitation) — via ATAD transposition (Law 4607/2019);
• Actions 8–10 and 13 (transfer pricing, CbCR) — via Law 4484/2017 and the Income Tax Code;
• Action 2 (hybrid mismatches) — via ATAD II (Law 4714/2020);
• Action 3 (CFC rules) — via ATAD (Laws 4607/2019 and 4714/2020);
• Action 6 (treaty abuse) — via the MLI and domestic GAAR (Law 4172/2013);
• Action 12 (disclosure) — via DAC6 (Law 4714/2020);
• Action 14 (dispute resolution) — via MAP upgrades;
• Action 5 (harmful tax practices) — via alignment of the IP, tonnage tax and investment-incentive regimes;
• Pillar Two — via Law 5100/2024.

Transparency has been reinforced through the Ultimate Beneficial Owner Register under Law 4557/2018.

13.2 Digital economy

Greece has not introduced a unilateral digital services tax, nor is one currently in contemplation. Instead, Greek policy tracks the EU and OECD framework on the taxation of the digitalised economy — emphasising the prevention of artificial PE avoidance and the alignment of transfer pricing outcomes with economic substance.

Greece has, however, developed targeted frameworks for:

• the taxation of short-term rentals on digital platforms;
• the transposition of DAC7 (Directive 2021/514/EU), imposing reporting obligations on digital platform operators in respect of the gross income earned by users.

On e-commerce permanent establishments, Greece has not subscribed to every OECD commentary position, preserving a degree of interpretive latitude — particularly on whether server infrastructure alone may constitute a PE.

13.3 Offshore IP

Royalties paid to offshore IP owners attract Greek withholding tax at 20%, subject to treaty mitigation and the EU Interest-Royalties exemption. Payments to recipients in non-cooperative or preferential jurisdictions are non-deductible unless the taxpayer can evidence genuine economic substance and the absence of profit-shifting.

14. Shareholder-Level Taxation: A Brief Note

For context, Greek tax-resident individuals are subject to:

• 5% income tax on dividends from Greek companies (applicable equally to closely held and listed entities);
• 15% income tax on capital gains from the disposal of shares in closely held corporations;
• generally, exemption from income tax on gains on the disposal of listed shares, except where the individual holds at least 0.5% of the share capital and acquired the shares on or after 1 January 2009 — in which case a 15% rate applies.

Employee stock options and share awards benefit from favourable capital gains taxation where minimum holding periods are satisfied, with a particularly generous 5% rate for qualifying start-up arrangements.

15. Strategic Observations for 2026 and Beyond

From our work advising Greek and international clients, a number of themes merit emphasis:

First, the centre of gravity of Greek corporate tax planning has shifted from rate arbitrage to substance-backed structuring. Greece’s participation exemption, patent box and strategic-investment regime are best exploited where the corporate footprint — people, assets, decision-making — matches the legal form.

Second, the interaction between Pillar Two and Greek incentives requires explicit modelling. For in-scope groups, advertised effective rates may no longer reflect the real fiscal cost after QDMTT.

Third, the 2025–2028 legislative cohort — the defence super-deduction (Law 5246/2025), the SME-listing deduction (Law 5193/2025), the unified reorganisation framework (Law 5162/2024) and the expanded participation exemption — constitutes a coherent pro-investment package that rewards well-structured, adequately documented transactions.

Fourth, audit intensity in transfer pricing and anti-abuse is rising. Documentation that discharges the taxpayer’s formal obligations is no longer sufficient; the analytical narrative — why the arrangement exists, what commercial function it serves, how it compares to third-party benchmarks — must be prepared with litigation in mind.

Fifth, for investors in real estate, renewables, data centres and advanced manufacturing, Greece’s alignment of incentive regimes with EU State aid rules has produced a more stable, if more technical, planning environment. The days of bespoke, politically negotiated reliefs are largely behind us; the days of disciplined, rules-based optimisation are firmly upon us.

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How Tsamichas Law Firm Can Assist

Tsamichas Law Firm advises Greek and international clients across the full spectrum of corporate taxation, including:

• inbound structuring and holding-company design;
• cross-border M&A and tax-neutral reorganisations under Law 5162/2024;
• transfer pricing documentation, defence and dispute resolution;
• strategic-investment applications, R&D and patent-box claims, and the defence super-deduction regime;
• tax audits, administrative appeals and litigation before the Greek tax courts and the Council of State.