Konstantina Kalakou Recent developments clearly show that the topic of permanent establishment (PE) is high on the Greek tax agenda. As per the practice followed to date by the Greek tax authorities, multinational entities that have a presence in Greece (through a subsidiary) do not often find themselves under the audit microscope provided that the Greek subsidiary has taxable revenues (commonly arising from services that the latter provides to other Group entities). On the other hand, commissionaire structures were scrutinised with the absence of contractual or negotiation authority on behalf of the agent, giving leeway for taxpayers. To this end, a ruling of the Court of Appeal has stated that a Greek agent that has been appointed only for promotion services of the foreign UK entity cannot trigger a PE.
February 01 2016