GREECE Law and Practice Contributed by: Theodoros Skouzos and Natalia Skoulidou, Iason Skouzos TaxLaw
Dividend Participation Exemption Intra-group dividends received by Greek legal entities are income-tax exempt when the following conditions are met: • the distributing company has a legal form listed in Annex I of the EU Parent-Subsidiary Directive; • it is EU tax-resident and not deemed resident in a third country under a tax treaty; • it is subject to one of the Directive-listed corporate taxes; • the Greek recipient holds at least 10% of shares, capital or voting rights; • this participation is maintained for 24 months (or secured by guarantee); and • the distributed profits were not deducted by the payer company. From tax year 2025, the exemption also applies to dividends from non-EU entities, provided the same 10%/24-month conditions are met, the distributing company is a capital company subject to CIT, and it is not located in a non-co-operative jurisdiction. Capital Gains Participation Exemption Greece exempts from income tax the capital gains earned by a Greek tax-resident legal entity from trans - ferring shares in EU (including Greek) subsidiaries, provided: • the subsidiary is EU tax-resident and has a legal form listed in Annex I of the EU Parent-Subsidiary Directive; • it is subject to one of the Directive-listed corporate taxes without exemption; and • the seller has held at least 10% of share capital or voting rights for 24 months. Related business expenses are non-deductible, and exempt gains are not taxed again upon distribution or capitalisation. From tax year 2025, the exemption also applies to non-EU subsidiaries, provided the participation meets the same conditions and the subsidiary is not located in a non-co-operative jurisdiction.
Other Taxes A capital concentration tax of 0.2% applies on sub - sequent contributions of capital (ie, not on the initial capital contributed upon the establishment of the company). Annual property taxes apply on property rights on real estate located in Greece, such as the Uniform Real Estate Tax (ENFIA) and the Special Real Estate Tax (SRET): • ENFIA is imposed on property rights (full/bare ownership, usufruct rights, etc) owned on January 1st of each year on real estate property located in Greece; and • SRET is imposed on Greek and foreign legal enti - ties owning real estate in Greece on January 1st of each year, at a tax rate of 15% on the objective tax value of the real estate, to corporations own - ing Greek real estate that do not disclose their ultimate beneficial owners, and that must also have acquired a Greek tax registration number. Real estate Taxes on the acquisition of real estate are as follows. • VAT at the standard rate of 24% is imposed on the purchase of real estate that qualifies as “new” (ie, whose building permit is issued or renewed on or after 1 January 2006) and is transferred prior to its first use. • RETT is imposed on the purchase of real estate not qualifying as new (or under the VAT suspen - sion regime). The effective tax rate (ie, RETT plus a municipality surcharge) is 3.09%, imposed on the higher of the sale price and the objective value of the real estate. VAT VAT is imposed on most supplies of goods and ser - vices. The standard VAT rate is 24%, applicable to all goods and services that are not subject to the reduced (13%) or super-reduced (6%) and (4%) VAT rates, which apply for specific goods and services explicitly enumerated in the law. All VAT rates are fur - ther reduced by 30% for certain Aegean islands under certain conditions.
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