GREECE Law and Practice Contributed by: Theodoros Skouzos and Natalia Skoulidou, Iason Skouzos TaxLaw
Digital Transaction Duty The Digital Transaction Duty (DTD) was introduced on 1 December 2024 and replaced stamp duty for many non-VATable transactions. Key changes include the removal of the territoriality principle: DTD applies wherever the contract is signed or performed, pro - vided at least one party is Greek tax-resident or has a Greek permanent establishment, and the transac - tion relates to that PE. The duty is imposed on the transaction, not the document. Typical DTD-subject
or after 11 April 2025 by Greek tax resident individuals from listed corporate bonds is reduced to 5% (from 15%). Royalties Royalties paid to non-resident companies are subject to 20% WHT, unless the foreign company has a PE in Greece. No WHT applies to royalties paid to resident companies or non-residents with a PE. Intra-EU/Swiss Payments Dividends, interest and royalties paid to EU or Swiss parent companies can be WHT-exempt if the par - ties meet the conditions of the EU Parent-Subsidiary Directive and the EU Interest-Royalties Directive. Non-EU Parents/DTTs Where the parent is non-EU or does not qualify for the participation exemption, an applicable double tax treaty (DTT) may reduce or eliminate WHT, and the DTT provisions will prevail over Greek domestic law. Services Consulting, management and technical service fees are subject to 20% WHT. However, service fees paid to Greek or EU/EEA companies (with or without a PE) are exempt. For non-EU/EEA companies, WHT applies only if they have a PE in Greece. Technical Projects Exception Fees for technical services paid to contractors under - taking technical projects are subject to 3% WHT, applicable to resident companies and non-residents with a PE. 9.3 Tax Mitigation Strategies Share Deals Most M&A transactions are structured as share acqui - sitions, due to a number of tax benefits, including: • exemption from indirect taxes (VAT, DTD); • exemption from real estate taxes on the transfer of companies holding real estate; • exemption from transfer taxes (with the exception of the transfer tax on listed shares); • exemption from capital gains tax on the sale of Greek shares by foreign non-resident corporate
transactions include: • commercial leases; • loans;
• deposits and withdrawals; • default/statutory interest; • assignments of receivables; • assumptions of debt; • transfers of businesses (if non-VATable); • settlements; • compensations; and • director/manager remuneration.
Many dealings with public-sector entities are also cov - ered. Rates are 0.3%, 1.2%, 2.4% or 3.6%, depend - ing on the transaction; most business transactions fall under the 2.4% rate, while commercial leases are typi - cally 3.6%. Some actions, such as licence issuance, incur a fixed duty. DTD does not apply to sales of shares, founders’ titles, bonds, dividends, debt secu - rities, or legal tender. Municipal taxes/environmental taxes Greece applies certain municipal and environmental taxes. 9.2 Withholding Taxes on Dividends, Interest, Etc Dividends Dividends paid to non-resident companies are sub - ject to 5% withholding tax (WHT). No WHT applies to profit distributions by partnerships using single-entry books, nor to remittances from Greek branches to their head office. Interest Interest paid to non-resident companies is subject to 15% WHT. The tax rate on interest income earned on
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