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
5.8 Tariffs Greece, as part of the European Union, is subject to the Union Customs Code (UCC). The aforementioned code was adopted in 2013, and its substantive provi - sions have applied since 1 May 2016, with the aim of bringing EU customs legislation into line with the requirements of the Lisbon Treaty. It supersedes the former Community Customs Code (CCC). Having said that, tariff classification is governed by the Combined Nomenclature (CN) and specific tar - iff classification decisions and updates are formally adopted through Commission Implementing Regula - tions. The European Commission updates this list on an annual basis, with the most recent revisions adding specific subheadings for advanced technologies such as batteries, photovoltaics, hydrogen, and advanced materials (Commission Implementing Regulation (EU) 2026/360 and Commission Implementing Regulation (EU) 2026/333). Countries with extensive trade agreements with the European Union benefit from significantly reduced or eliminated tariffs, creating heavily integrated market access. For example, the EU–South Korea Free Trade Agreement has eliminated customs duties on nearly all goods traded between the parties. In addition, it has reduced numerous non-tariff barriers affecting exports of products such as automobiles, pharmaceuticals, electronics, and chemicals. The agreement has also liberalised a wide range of services sectors, facilitating market access and investment opportunities for both EU and South Korean businesses. Another example is the EU–Central America Association Agreement, which has been provisionally applied since 1 August 2013 with Honduras, Nicaragua, and Panama; since 1 October 2013 with Costa Rica and El Salvador; and since 1 December 2013 with Guatemala.
arm’s length principle must be applied and interpret - ed in line with the general principles and the OECD Transfer Pricing Guidelines in relation to intra-group transactions. Transfer pricing rules apply to transactions between “related parties” as defined under the GITC. Greek tax legislation adopts a broad definition of related parties, covering both direct and indirect relationships that may influence the pricing of intra-group transactions. In more detail, a 33% threshold is applied to deter - mine related-party status, based on direct or indirect participation in capital or voting rights. In addition, parties may also be treated as related where one enti - ty exercises managerial control or decisive influence over another, regardless of whether any participation in capital or voting rights exists. 5.7 Anti-Evasion Rules Greece has introduced Controlled Foreign Corporation (CFC) rules, a General Anti-Abuse Rule (GAAR), and hybrid mismatch provisions in accordance with ATAD I and II, whereas there are special anti-avoidance rules regarding the taxation on corporate transformations. The GAAR applies to both domestic and cross-border arrangements, provided that the relevant double tax treaty does not contain its own anti-abuse provisions, such as a Principal Purpose Test. Under this rule, the Greek tax authorities may disregard arrangements or series of arrangements that are primarily, or have as one of their main purposes, the obtaining of a tax advantage that contradicts the intent or purpose of the applicable tax law. Under the revised CFC framework, even where all applicable conditions are met, the rules will not apply if the foreign entity is located in an EU or EEA juris - diction and demonstrates genuine economic activity, such as having sufficient staff, premises, assets, and equipment. Lastly, the hybrid mismatch rules aim to prevent dou - ble deductions or deductions without corresponding taxation arising from differences in the tax treatment of entities or instruments across jurisdictions, thereby safeguarding against base erosion.
6. Competition Law 6.1 Merger Control Notification
Greek merger control is governed by Law 3959/2011 (the “Greek Competition Act”), which is closely aligned with the EU Merger Regulation (EUMR). The system is primarily administered by the Hellenic Competition Commission (HCC) and operates on a mandatory and
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