GREECE Law and Practice Contributed by: Theodoros Skouzos and Natalia Skoulidou, Iason Skouzos TaxLaw
• legislative fluidity; • slow courts; and • obstacles in spatial planning and environmental permitting. Greece is therefore seen to be improving but is still administratively demanding for investors. Main FDI Sectors The key sectors attracting FDI include: • real estate and hospitality; • renewable energy and grid infrastructure; • transport, logistics and ports; • financial services and fintech; and • manufacturing and ICT/data centre operations. Incentives Greece offers a “Fast-Track” strategic investment regime with accelerated licensing and tax benefits, blended financing linked to the Recovery and Resil - ience Facility (RRF) for green and digital projects, and sector-specific incentives including renewable energy systems, R&D and logistics tools, alongside the gold - en visa programme. FDI Regulation Traditionally, Greece applied an open-door policy with national treatment for foreign investors, and restrictions only in areas such as defence, media and certain critical infrastructure. In May 2025, however, Greece adopted Law 5202/2025, its first comprehen - sive FDI screening system implementing EU Regula - tion 2019/452. The regime is new, significant and still untested in practice. 3. Mergers and Acquisitions 3.1 Transaction Structures The most common structures for a transaction involv - ing targets in Greece are as follows: • the acquisition of shares in a target company; • setting up a special purpose vehicle in a jurisdic - tion that has a strong corporate law culture and a double taxation treaty with Greece, which then buys the assets or the shares of the target; and
• setting up a Greek corporation (either an S.A. or an IKE company). The key considerations in selecting a transaction are as follows: • the duration of the investment/exit horizon; • involvement in the management of the target; • immigration law considerations, as there are facili - tations in relation to work permits for directors of Greek entities in certain cases; and • tax treatment. The choice of structure does not have significant dif - ferences between the acquisition of public versus private companies, nor between the acquisition of companies compared to making minority investments. 3.2 Regulation of Domestic M&A Transactions For a foreign investor looking at M&A in Greece, the main regulatory “gates” to think about are: • merger control (competition law); • the new Greek FDI screening regime (Law 5202/2025); • the EU Foreign Subsidies Regulation (FSR); • sector-specific and prudential approvals in Greece (see 8.1 Other Regimes ); and • capital markets/public M&A rules (if the target is listed). If the target is listed on the Athens Exchange, the fol - lowing applies: • takeover bids are governed by Law 3461/2006 (implementation of the EU Takeover Directive), with mandatory bid obligations once certain control thresholds are crossed; • transparency and major holdings notifications under Law 3556/2007 (and related rules) kick in at various voting rights thresholds; and • the Hellenic Capital Market Commission (HCMC) is the key regulator for both. These are no “approvals” in the strict sense, but pro - cedural constraints and disclosure obligations that drive deal design and timetables may be imposed.
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