All material subject to strictly enforced copyright laws. © 2022 ITR is part of the Euromoney Institutional Investor PLC group.

Greece: APA regime just around the corner


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 (

Ernst & Young

Tel: +30 210 2886381


more across site & bottom lb ros

More from across our site

Vikas Garg talks to reporter Siqalane Taho about how regulation, technology and the goods and services tax has affected the manufacturing company.
A major shift is underway in tax as the profession transitions from a mostly accounting and finance sector to a hybrid industry that requires significant IT skills, say tax experts.
The Biden administration is about to give $80 billion to the Internal Revenue Service to enhance the tax authority’s enforcement processes and IT systems.
Audi, Porsche, and Kia say their US clients will face higher prices under the Inflation Reduction Act after the legislation axes an important tax credit for electric vehicle production.
This week Brazil’s former President Luiz Inacio Lula da Silva came out in support of uniting Brazil’s consumption taxes into one VAT regime, while the US Senate approved a corporate minimum tax rate.
The Dutch TP decree marks a turn in the Netherlands as the country aligns its tax policies with OECD standards over claims it is a tax haven.
Gorka Echevarria talks to reporter Siqalane Taho about how inflation, e-invoicing and technology are affecting the laser printing firm in a post-COVID world.
Tax directors have called on companies to better secure their data as they generate ever-increasing amounts of information due to greater government scrutiny.
Incoming amendments to the treaty could increase costs on non-resident Indian service providers.
Experts say the proposed minimum tax does not align with the OECD’s pillar two regime and risks other countries pulling out.
We use cookies to provide a personalized site experience.
By continuing to use & browse the site you agree to our Privacy Policy.
I agree