GREECE Law and Practice Contributed by: Maria Zoupa, Daphne Cozonis, Ioanna Tapeinou and Diana Tsourapa, Zepos & Yannopoulos
Investments to include green, innovative, and low‑car - bon projects – ranging from renewables and hydrogen systems to offshore wind and floating PV. The scope now also spans critical raw materials, circular econ - omy initiatives, shipbuilding, and other activities that strengthen Greece’s position in globally competitive industries. Strategic investments would mostly embrace innova - tion, competitiveness, comprehensive planning, the preservation of natural resources in the context of the circular economy, and high added value – notably in the business sectors of international trade and ser - vices. The available tax incentives offered (which may vary by category of investment project but typically include): • the stabilisation of the tax rate for 12 years; • income tax deferral; • accelerated depreciation; • beneficial taxation for expatriate executives; and • tax exemptions (that may be used over a period of up to 15 years) Defence A new super-deduction regime has been introduced by Article 13 of Law 5246/2025 aiming to support investment in defence-related and allied manufactur - ing units. This includes a 100% super-deduction for qualifying capital expenditure, applicable to all enter - prises with a registered seat or branch in Greece. The initial investment must be made in 2026, 2027, or 2028, and the project needs to be maintained in an eligible region for at least five years following comple - tion. Non-compliance may result in the revocation of the tax benefit, with the amount of the claimed super- deduction becoming repayable. The regime operates in line with Commission Regulation (EU) 651/2014 and the General Block Exemption Regulation (GBER), ensuring compatibility with the internal market. Listing of SMEs Costs incurred for the listing of very small, small and medium-sized enterprises (SMEs) on the stock exchange shall be deductible for tax purposes at the time of their realisation increased by 100%, whereas the maximum amount of tax benefit shall not exceed
EUR200,000 per Article 24 of Law 5193/2025 (adding a new Article 22ΣΤ to the Greek Income Tax Code). The tax incentive covers costs that are directly related to the process of bringing an SME to the regulated market, including: • due diligence and professional audits (legal, finan - cial, tax) required for the listing process; • advisory and co-ordination fees paid to intermedi - aries or consultants managing the listing process; • taxes, charges and statutory fees directly arising from the listing; • prospectus preparation and printing; and • other related documentation costs necessary for admission to the regulated market. To qualify for the enhanced deduction, the shares or equivalent listed titles must remain listed on the regulated market for at least ten consecutive years. If they are held for a shorter period, the benefit may be reversed in whole or in part. The enhanced tax deduction applies to qualifying expenses incurred during tax years 2025, 2026 and 2027. 2.4 Loss Relief Tax losses incurred by the conduct of a business within a certain fiscal year can be carried forward to be offset against profits made during the next five consecutive years. Previously untaxed profits that are taxed as a result of their distribution or capitalisation cannot be offset against tax losses incurred in the relevant year. No carry back is currently available in Greece. Moreover, no group relief is currently available in Greece. Tax losses incurred abroad can neither be used to determine taxable profit in the same fiscal year nor carried forward – with the exception of tax losses arising from the conduct of business through permanent establishments in EU/EEA member states, provided that the relevant profits are not exempt from Greek income tax by virtue of a double taxation treaty between Greece and the relevant EU or EEA member state.
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