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Taxes in Greece

Corporate taxation

Taxes on entities

Greek companies are taxed on their worldwide income. Non-Greek companies are taxed in Greece only on income derived from a permanent establishment in Greece or on profits generated in Greece.

Residence and non-residence

A legal person or entity is considered to be a Greek tax resident in the following cases:

  • it is incorporated or established under Greek law;
  • it has its registered office in Greece;
  • its place of effective management is in Greece at any time during the tax year.

The “place of effective management” concept should be examined separately and its determination depends on the facts and circumstances of the case. Indicative criteria are the following:

  • the place where the day-to-day management of the company takes place;
  • the place where strategic business decisions are made;
  • the place where the annual general meeting of shareholders or partners or the board of directors takes place;
  • the place where the accounting books of the company are held;
  • the residence of the members of the corporate body (e.g. boards of directors of the company).

Also, depending on the case, additional factors might be examined by the Greek Tax Authorities, such as the residence of the majority of the shareholders or partners.

Tax year and filing

The fiscal year starts on 1 January of a calendar year and ends on 31 December of said year.

Legal persons or entities that maintain double-entry books may set their tax year to end on another date in order to coincide with the tax year-end of their foreign

shareholder. However, a tax year cannot exceed a 12 month period. Greek legal entities and branches of non-Greek companies established in Greece must file an annual corporate income tax return by the end of the sixth month following the end of the relevant fiscal year.

Types of income

All the income that incur at the level of the legal entities is considered, from a tax point of view, as income from business profits. The tax base is formed by the annual gross income after certain deductions. In particular, ordinary business expenses and specific items mentioned in the tax legislation can be deducted for tax purposes provided the following conditions are fulfilled:

  • they are made in the interest of the business or in the ordinary course of its business transactions;
  • they reflect an actual transaction that has a value not considered lower or higher than the actual value, based on indirect audit methods;
  • they are recorded in the accounting books for the period in which they are incurred and are supported by proper documentation.

Further, as per the tax legislation there are certain expenses that shall not be tax-deductible.

Group income and grouping arrangements

Capital gains

Capital gains income incurred at the level of legal entities is taxed as business profits and it derives from the following sources:

  • disposals of fixed assets;
  • transfers of businesses as going concerns;
  • disposals of real estate property that do not constitute a business activity per sector;
  • transfers of securities.

 Losses

The tax losses that arise at the level of legal entities can be carried forward in order to offset business profits of said entities in the following 5 fiscal years as from the fiscal year in which they arise.

Double tax relief

According to the Greek tax legislation, foreign tax paid or deducted on foreign source income is credited against Greek tax liability on the same income. The amount of foreign tax credit cannot exceed the amount of tax that would be payable in Greece for the same foreign source income.

Said relief from double taxation may be also available due to the application of the relevant double tax treaty. Greece has signed approximately 56 double tax treaties up to now.

Exemptions

Inbound dividends that are received by Greek legal entities from substantial shareholdings could be exempt from corporate income tax in Greece, provided certain conditions are cumulatively fulfilled which are related to the application of the Parent/Subsidiary Directive, as incorporated (and amended) in the Greek legislation.

Profits arising outside of Greece at the level of a permanent establishment of a Greek Company established in another country could be exempt from taxation in Greece, provided there is a double tax treaty signed between Greece and the country where the permanent establishment is located.

Rates

The corporate income tax rate in Greece is 29%.