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 2026

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

Lindsay Clayton’s arrival at Baker McKenzie continues the firm’s storied pursuit of ex-US government lawyers, a strategy reinforced by robust World Tax rankings
Shared transaction semantics, governed data and reusable ERP design may prove the most significant benefits of the UK's move to Peppol
As pillar two reshapes global tax competition, the UK faces a crucial challenge: how to remain attractive to multinationals without sacrificing tax revenues
Pillar two may be raising less than expected, but professor René Matteotti says the regime is still changing multinational tax behaviour
Multinationals importing goods into Brazil may need to align TP files and customs documentation more closely as authorities gain new tools to challenge related-party transactions
The private equity-backed deal hands Grant Thornton immediate and impressive US scale, but World Tax data suggests the firm still has work to do to gain recognition
From Instagram content to £100m transactions, the founder of Thomas & Co International discusses building a modern tax and accounting firm for business founders
Growing GAAR scrutiny is driving taxpayers to look beyond legal form and demonstrate the commercial rationale underpinning tax-efficient structures
Pillar two has been clients’ ‘biggest headache’ but also a driver of growth for MHA, which believes it has the edge over its big four rivals
Public country-by-country reporting is exposing multinational tax data to investors, journalists and competitors, creating fresh risks for businesses
Gift this article