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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.

Amendments to Law 4110/2013:

The Tax Authority has the right to retroactively request the Transfer Pricing Documentation Files of companies that had the obligation under the provisions of Article 26 of Law 3728/2008 of the Ministry of Development to document their intercompany transactions within financial years 2008-2009. The Documentation Files will be audited by the Tax Authority according to the applicable provisions of each period.