Greece: Favourable tax regime for shared service offices

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Greece: Favourable tax regime for shared service offices

grigoriou.jpg

Georgia Grigoriou

Greek law 89/1967 (L.89), as now in force, includes provisions aiming to attract foreign investments to Greece by granting the qualifying entities a special cost–plus tax regime (pre-agreed with the tax authorities), following a special advance pricing procedure. Such regime has been in force since 2006. Specifically, this special tax regime applies to local entities and branches of foreign enterprises, exclusively engaged in providing certain qualifying services (for example, consulting, accounting, advertising, marketing, data processing and/or R&D services) to other associated entities established outside Greece and to their head offices abroad. A L.89 office is established after obtaining a special license granted by the Ministry of Finance (MoF) and must employ at least four persons while its operating expenses must be at least €100,000 per year and covered by direct funding from the company established outside Greece.

The gross income of L.89 offices is calculated with the application of a cost-plus method whereby all the expenses, on which the mark-up applies, are deductible for tax purposes provided they are supported by fiscal documents issued in compliance with Greek statutory rules. The taxable mark-up (which cannot amount to less than 5%) is determined on a case-by-case basis by the MoF after an application is submitted by the company supported by a relevant benchmarking study and is subject to the standard CIT rate of 26%. Said tax ruling is reviewed every five years or earlier in case of significant market condition alterations. Furthermore, it should be noted that special incentives also apply in case of L.89 expatriate personnel.

Regarding recent developments, a ministerial decree published on December 31 2014 provides the penalties arising in the case of infringements of the respective legislation or of the provisions of the special licence granted approving the establishment or qualification of the L.89 office. The legal representatives of the company in Greece are held jointly liable for the payment of the aforementioned penalties.

Georgia Grigoriou (georgia.grigoriou@gr.ey.com)

EY

Tel: +30 210 2886381

Website: www.ey.com

more across site & shared bottom lb ros

More from across our site

New hires from rivals are reportedly being axed from the firm, following a steep decline in profits
Following Richard Houston’s switch to the newly formed Deloitte EMEA, Graves has the opportunity to bring Deloitte’s tax practice up to speed with its rivals
Firms announced tax hires and promotions across Europe and the US, while fresh figures from Ireland showed corporation tax receipts edging down in the first quarter
The country has overseen better audit procedures and demonstrated commitment to acting as a 'regional leader' on international tax matters, the OECD said
Barrister Setu Kamal and policy guru Dan Neidle have clashed over the former’s legal action against Google, described as ‘bonkers’ by Neidle
Authors from Khaitan & Co evaluate the recent CBDT notification, whereby legacy investments made by investors continue to be exempt from the applicability of GAAR
Dual-qualified corporate tax specialist Christoph Schimmer joins the firm after stints at Deloitte, Cerha Hempel and DLA Piper
Geopolitical rivalry is reshaping global tax cooperation, as the OECD’s minimum tax framework fragments and the EU grapples with the ensuing legal fallout
LED Taxand’s partner tells ITR about entrepreneurial inspirations, the importance of people skills, and what makes tax cool
Shiny new offices like Ryan’s in London Bridge aren’t just a cost – they signal that a firm is willing to align with its clients’ interests
Gift this article