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Greece: Favourable tax regime for shared service offices

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 (
Tel: +30 210 2886381

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