Greece: APA regime just around the corner

International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

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

Greece: APA regime just around the corner

angelou.jpg

Laura Angelou

In the current economic context, the Greek tax authorities are eager to obtain greater tax revenues and transfer pricing is an area Greece can focus on to improve its tax yield. The Greek tax administration deeply scrutinises cases of loss making controlled transactions, saying that the actual prices should have been lower or higher and that more profit should have been offered by the local company.

It is also possible that in cases of loss making intra-group transactions, the Greek tax authority will make a claim that a percentage of the expenses incurred by the controlled transactions should not be considered as tax deductible, while maintaining an analogy between loss and non tax deductible expense amounts.

With the Greek tax administration focusing its attention on transfer pricing and enhancing the relevant audit teams with experienced and well-equipped tax professionals, multinational enterprises (MNEs) operating in Greece are reviewing their intra-group transactions and transfer pricing policies. Though filing transfer pricing documentation helps MNEs in mounting a strong defence and reduces their tax exposure, on its own it may not result in complete elimination of double taxation.

To avoid this tax uncertainty, and as a result of long lasting discussions between tax authorities, MNEs and tax firms with regard to Greek tax reform, the advance pricing arrangement scheme (APA scheme) has been approved by the Greek Parliament and is to be introduced as of January 1 2014.

Although specific guidelines for the application of the APA scheme have not been issued under the existing tax law provisions, the option of obtaining an APA can be characterised as being of a preventive nature.

Under the APA scheme, taxpayers and tax authorities will negotiate in advance the methodology of specific future intra-group transactions, following an application submitted before the General Directorate of Tax Audits and Collection of Public Revenue of the Ministry of Finance.

Specific rules on the application of the APAs are expected before year-end. The scheme should bring tax certainty, reduce litigation expenses and avoid the risk of double taxation, while bringing in extra revenue for the tax administration.

Laura Angelou (laura.angelou@gr.ey.com)

Ernst & Young

Tel: +30 210 2886381

Website: www.ey.com/gr

more across site & shared bottom lb ros

More from across our site

The arrival of a seven-strong team from Baker McKenzie will boost WTS Germany’s transfer pricing capabilities and help it become ‘a European champion’, the firm’s CEO said
Germany has forgotten to think about digital reporting requirements, a WTS partner claimed at ITR’s Indirect Tax Forum 2025
E-invoicing is currently characterised by dynamism, with fragmentation acting as a key catalyst for increasing interoperability, says Aida Cavalera of the International Observatory on eInvoicing
Pillar two and the US tax system ‘could work in harmony’, Scott Levine tells ITR in an exclusive interview to mark his arrival at Baker McKenzie
Peter White, who has a tax debt of A$2 million, has been banned for five years from seeking registration with Australia’s Tax Practitioners Board (TPB)
Wopke Hoekstra’s comments followed US measures aimed against ‘unfair foreign taxes’; in other news, Grant Thornton and Holland & Knight made key tax partner hires
An Administrative Review Tribunal ruling last month in Australia v Alcoa represents a 'concerning trend' for the tax authority, one expert tells ITR
A recent decision underlines that Indian courts are more willing to look beyond just legal compliance and examine whether foreign investment structures have real business substance
Following his Liberal Party’s election victory, one source expects Mark Carney to follow the international consensus on pillar two, as experts assess the new administration
A German economics professor was reportedly ‘irritated’ by how the Finnish ministry of finance used his data
Gift this article