Greece: APA regime just around the corner

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: 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

Geopolitical rivalry is reshaping global tax cooperation, as the OECD’s minimum tax framework fragments and the EU grapples with the ensuing legal fallout
LED Taxand’s partner tells ITR about entrepreneurial inspirations, the importance of people skills, and what makes tax cool
Shiny new offices like Ryan’s in London Bridge aren’t just a cost – they signal that a firm is willing to align with its clients’ interests
Darren Graves will succeed Richard Houston, who is set to lead Deloitte EMEA; in other news, Morgan Lewis hired a three-partner tax team in New York
India also signed its first-ever bilateral APAs with France, Ireland, Indonesia and Sweden last year, the CBDT revealed
Chile’s revamped GAAR marks a shift toward structural scrutiny, pushing MNEs to strengthen tax governance, economic substance and compliance strategies
New reforms represent the most seismic shift in Canadian TP legislation since its enactment and a clear inflection point for MNEs, ITR has heard
Spain did not transpose EU VAT rules for SMEs or works of art; in other news, an increased VAT threshold came into force in South Africa
While the IBS incorporates taxable events previously covered by state and municipal taxes, its governance and operational logic represent a significant departure from the legacy model
The new office on the fourth floor of 4 More London will span 14,230 square feet, with the potential to expand to the first and second floors
Gift this article