GREECE Law and Practice Contributed by: Anastasia Dritsa, Elisabeth Eleftheriades, Vicky Kriketou, Irene Kyriakides, Ioanna Kyriazi, Victoria Mertikopoulou, Claire Pavlou and Panagiotis Pothos, Kyriakides Georgopoulos Law Firm
framework for multinational groups and large-scale domestic groups. Under this regime, the GloBE Information Return (GIR) must generally be filed within 15 months after the end of the relevant reporting fiscal year (or 18 months for the transitional year). The corresponding tax return must then be filed by the last working day of the month following the submission of the GIR. The law introduces the QDMTT safe harbour, the CbCR transitional safe harbour, and the UTPR tran - sitional safe harbour. It also expressly provides that these safe harbours are to be interpreted in line with the OECD Model Rules. VAT Considerations VAT is imposed on all transactions for consideration involving the supply of goods and the provision of services. The standard VAT rate is 24%, although reduced rates also apply in certain cases. Digital Transaction Duty (DTD) The DTD is a tax introduced in Greece through Law 5135/2024 and codified by Law 5177/2025, imposing a proportional levy on specific transactions that fall outside the scope of VAT. The DTD applies to transac - tions where at least one party is a Greek tax resident or has a permanent establishment in Greece, provided that the transaction is connected to that establish - ment. The duty is calculated as a specific percentage of the financial value of the transaction or the highest debit/credit balance. Special Real Estate Tax (SRET) The ownership of Greek real estate through non-trans - parent structures is addressed through the imposi - tion of a special tax on property held as of 1 January each calendar year, calculated at a rate of 15% on the imputed/statutory value of the real estate. In prac - tice, the tax does not apply to a significant number of incorporated entities holding real estate in Greece due to various exemptions, particularly where the owning company is not considered to be used as a vehicle for tax evasion or avoidance. Recent amendments to the special real estate tax framework have aligned the exemption for regulated investment vehicles with
applicable domestic and EU legislation governing such schemes. Unified Real Estate Tax (URET) The URET (ΕΝ.Φ.Ι.Α.) constitutes an annual property tax imposed on all real estate situated in the country. It is calculated on the basis of objective property val - ues, considering factors such as floor area, age, and location, with main tax rates for buildings ranging from EUR2 to EUR16.20 per square metre. Capital Concentration/Accumulation Tax CCT is levied at a flat rate of 0.2% on contributed capital, including share capital increases made in cash or in kind. This duty applies to commercial companies and corporate transformations, rather than to the ini - tial establishment of a company. Listed Shares Sales Tax Capital gains arising from the sale of listed and unlist - ed shares are treated as business income and are subject to corporate income tax at the standard CIT rate. However, where such gains are realised by for - eign legal entities tax resident abroad, they are taxable in Greece only to the extent that the entity maintains a permanent establishment in Greece to which such gains can be attributed. In addition, the transfer of listed shares is subject to a transaction duty at a rate of 0.1%. The GITC introduces tax incentives in the form of enhanced “super” deductions for specific business expenses. Scientific and technological research costs, including depreciation of related equipment, are deductible with a 100% uplift. Similar enhanced deductions apply to expenses related to the green economy, energy efficiency, and digitalisation for SMEs, as well as to costs connected with the listing of SME shares or equivalent securities on a regulated Greek market, also with a 100% uplift and a cap on the resulting tax benefit of EUR200,000. The provision aims to encourage investment in research, sustain - able development, digital transformation, and capital market participation. 5.3 Available Tax Credits/Incentives Incentives Offered for All Enterprises
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