Transfer Pricing

• Transfer pricing planning and compliance advice
• Preparation of Documentation Sheets and Interservice Transaction Matters
  Fines / violations of intra-group transactions
• Advice and assistance in preparing transfer pricing documentation in accordance to Greek or foreign legislation
• Assistance in transfer pricing audits
• Benchmarking reports
• Support during tax audit for transfer pricing
• APA’s – Pre-approval of intra-group transactions

Amendments to Law 4172/2013 and Law 4174/2013:

• It is now clarified that legal persons and legal entities, as defined by Law 4172/2013, must document transactions with associated persons as these are defined in Article 2 of Law 4172/2013 (Transfer Pricing rules).
•  It is not stipulated whether a threshold (minimum amount) will apply per type and per counterparty for transactions that must be documented.
•  The deadline for the preparation of the Transfer Pricing Documentation File and the electronic submission of the Summary Information Sheet is extended to 4 months after the end of each tax year.
• A penalty at the rate of 1% of the entity’s recorded gross revenues is imposed in case of submission of an inaccurate or incomplete Summary Information Sheet.
• The decision to be issued by the General Secretariat will also determine, among others, a simplified documentation process for small and medium sized enterprises.