GREECE Law and Practice Contributed by: Maria Zoupa, Daphne Cozonis, Ioanna Tapeinou and Diana Tsourapa, Zepos & Yannopoulos
9.3 International Tax International tax has a high public profile in Greece, most notably with regard to transfer pricing and the general objective of transparency. In general, Greece tends to adopt BEPS recommendations fully and con - servatively. At the same time, however, Greece’s focus is on protecting the tax base, ensuring transparency, and demonstrating a fair and modern tax system. 9.4 Competitive Tax Policy Objectives Greece implements BEPS measures, prioritising transparency, fairness, and protection of the tax base. Maintaining competitiveness is expected to rely on non‑BEPS‑sensitive incentives, such as investment credits, employment subsidies, R&D deductions, accelerated depreciation, participation exemptions and sector‑specific regimes explicitly permitted under EU rules, as further outlined in the above sections. These measures would support economic growth without undermining minimum taxation or anti‑avoid - ance standards. 9.5 The Competitive Tax System In principle, Greece’s competitive tax offerings are increasingly shaped – and limited – by BEPS measures and EU State aid rules, as transposed into domestic legislation. The areas most exposed to challenge are those that could be viewed as offering a selective advantage, encouraging profit shifting, or undermin - ing minimum taxation standards. Special regimes that offer reduced effective tax rates or exemptions – such as incentives for holding companies, shipping‑related entities (outside the EU‑approved tonnage tax), or sector‑specific corporate tax reductions – are more vulnerable to challenge. In general, Greece’s competitive strategy increas - ingly focuses on broad, non-selective incentives (eg, investment deductions, R&D support) and on main - taining a stable, transparent tax environment rather than offering low rate or preferential tax regimes. 9.6 Hybrid Instruments and BEPS Implementation Applicable as of 1 January 2020, hybrid mismatch rules were transposed into domestic legislation. The relevant provisions introduce an obligation to disallow
Mandatory Disclosure Rules (DAC6) By virtue of Law 4714/2020, Greece transposed into its domestic legislation, Council Directive (EU) 2018/822 adopted on 25 May 2018 amending Direc - tive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation in rela - tion to reportable cross-border arrangements (DAC 6). Alignment of Preferential Regimes and Harmful Tax Practices Amendments to domestic legislation modernised Greece’s preferential tax regimes in line with BEPS Action 5 and EU State aid rules, affecting the ton - nage tax system, IP regimes, and investment incentive frameworks. 9.2 Government Policy and Objectives Approach Greece is a member of the Inclusive Framework on Base Erosion and Profit Shifting and views BEPS not only as a compliance requirement but also as a stra - tegic tool to strengthen the tax system, improve fiscal stability and battle tax evasion and avoidance. Law 5100/2024 transposed into Greek legislation the EU Council Directive 2022/2523 on establishing a global minimum level of taxation for multinational enterprise groups and large‑scale domestic groups within the European Union (Pillar Two). The Law closely follows the EU Directive by introduc - ing two interlocked rules, the income inclusion rule (IIR) and the undertaxed profit rule (UTPR) designed to bring the effective tax rate of in-scope groups up to the agreed minimum effective tax rate of 15% through a top-up tax. Greece also adopts a domestic top-up tax so that it can collect taxes on low-taxed entities operating within its territory. As regards Pillar 1, it is not currently anticipated to be enacted in Greece until the OECD’s Multilateral Convention (MLC) is finalised, signed, and entered into force globally. The allocation of taxing rights for MNEs to end-market and source jurisdictions if this progresses, may have a positive impact on fiscal rev - enues in Greece going forward.
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