Greece introduces amendments to the taxation of ships

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

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

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

Greece introduces amendments to the taxation of ships

Sponsored by

eygreece.png
ferry-4607185-1920.jpg

Evgenia Kousathana of EY Greece summarises the key changes in the shipping industry that the Greek government introduced through L. 4646/2019.

In the context of the tax reform introduced by L. 4646/2019 to most areas of the Greek tax legislative framework, significant shipping taxation amendments have also entered into force as of January 1 2020.

Under the new shipping tax law provisions, the Greek tax legislator has also expanded the tonnage tax regime to bareboat chartering and ship leasing by amending Article 25 of L. 27/1975. This provides the legal framework for the establishment of offices and branches of foreign shipping companies in Greece through the introduction of two new articles (26B and 26C) to L. 27/1975.

In particular, for tax years as of January 1 2020, offices of foreign enterprises dealing with the representation of bareboat charterer or ship lessee companies, now explicitly fall within the scope of the tonnage tax regime. In addition, the rights and obligations arising from the exploitation of ships under the tonnage tax regime have been extended to bareboat charterer companies and ship lessees, as well as their ultimate shareholders, up to the level of the private individual shareholder.

As a result, starting January 1 2020, the payment of tonnage tax exhausts any further tax liability with respect to any tax, tax duty, contribution or withholding for foreign-sourced income arising from the ship’s exploitation, for the shipowner company, as well as the bareboat charterer company, the ship lessee company or the company owning the ship with a foreign flag (which is administered or exploited by a Greek L. 27/75 ship management company).

However, ship leasing companies are explicitly excluded from the application of tonnage tax regime.

With respect to the payment of tonnage tax, the management companies are jointly liable for the payment of the tax, alongside the ship owning companies or the bareboat charterers, or the ship lessees that granted them the relevant management and administrative rights. In cases of more than one company established in Greece in accordance with L. 27/1975, managing the ship, they are all severally liable for the payment of the tax. 


In addition to the above-mentioned changes, the provisions of L. 791/1978, regarding the criterion of the statutory (and not of the real) seat, were also amended, so as to be applicable to bareboat charterers or ship lessees, as well. Therefore, the seat of bareboat charterers or ship lessees is defined by reference to their articles of association.

By virtue of these amendments, the tax treatment of the income arising from the ship’s exploitation, irrespective of the existence of the ship ownership rights, have been harmonised. This approach is aligned with the developments in the shipping industry, since bareboat chartering and ship leasing are long established ways of ship exploitation. 





Evgenia Kousathana

E: evgenia.kousathana@gr.ey.com





more across site & shared bottom lb ros

More from across our site

Recent news of job cuts at EY is symptomatic of how the PwC controversy has tarnished the reputation of the entire ‘big four’
Experts reportedly discussed extending the safe harbour to 2027 to give countries more time to legislate; in other news, Baker McKenzie and Greenberg Traurig made senior tax hires
Awards
Submit your nominations to this year's WIBL Americas Awards by January 23
Recent changes in UK tax rules and cross-border requirements are generating high demand for specialist advice, according to MHA
Hany Elnaggar examines how Gulf Cooperation Council countries are internalising transfer pricing norms within evolving fiscal systems shaped by both Islamic and international influences
Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default
EY, KPMG, Deloitte, and PwC have all seen a decrease in public sector contracts since the scandal – it is understood
Consoli, a tax partner at Brazilian law firm Martinelli Advogados, tells ITR about the importance of staying at the coalface and constantly learning
Despite legislative gridlock, international investors should be wary of legal precedents set by recent court rulings, which could substantially alter the Spanish tax environment
The new outfit, Ashurst Perkins Coie, will bring together around 3,000 lawyers across 23 countries
Gift this article