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Tax Guide

Financial Year – 1 January – 31 December
Currency – Euro (EUR)

Corporate Tax Summary

Basis for Taxation – Legal entities and their shareholders are required to register with the Greek tax authorities and obtain a unique Tax Identification Number (AFM) to carry out business in Greece.

Resident companies are taxed on their worldwide income, while non-resident companies are taxed in Greece only on income derived from Greek sources.

Residence – A legal entity is considered a Greek tax resident when one of the following conditions is met:
The legal entity has been incorporated or established according to Greek legislation
It has its legal seat or registered offices in Greece
Its place of effective management is in Greece.

Permanent Establishment – A foreign legal entity is a tax resident in Greece if it has a Permanent Establishment (PE). A PE includes:

  • a) A place of management
  • b) A branch
  • c) An office
  • d) A factory
  • e) A workshop
  • f) A mine, an oil or gas well, a quarry or any other place of natural resource extraction.
Reference
Corporate Income Tax Rate (%) 22% Corporate income tax rate is reduced to 22% from 2021 onwards.
Decrease of Income Tax prepayment
The rate of income tax down payment for free lancers is reduced from 100% to 55%. The prepayment is assessed based on the income tax return of tax years 2020 onwards.The rate of income tax down payment for legal persons and legal entities is reduced from 100% to 80% for the income tax returns of the tax years 2021 onwards.
Withholding Tax Rate:
Dividends 5%
Interest 15%
Royalties 20%

Intra-group payments for dividends, interest and royalties received by other EU parent entities are exempted from withholding taxes, provided that:
– the legal entity making the payments and the recipient qualify under the conditions set by Directive 2011/96/EU and Directive 2003/49/EU.
In the case of a non-EU parent entity and/or when the parent company does not qualify for the participation exemption rule, the provisions of double tax treaties will be applicable and prevail over Greek tax law.

Deductible Expenses
As a rule, all business expenses are deductible to define net income subject to taxation, provided that the following conditions are cumulatively met:
Expenditure is evidenced and supported by the proper documentation and invoices, incurred for business purposes, and carried out within the course of ordinary business activities. Additionally, all expenses must be recorded into accounting books in the corresponding period.
The Income Tax Code specifies that specific expenses are non-deductible under certain conditions, while special rules apply to super deductions for research and development expenses (R&D).

Tax Losses Carried Forward:
Losses may be carried forward for a maximum of 5 years. Greece has adopted the stand-alone approach for corporate groups and does not provide any legislation for group taxation.

Offsetting tax losses incurred abroad against business profits derived in Greece is not permitted, with the exception of income arising in other EU or EEA member states which is non-exempt according to the applicable double tax treaties.

Transfer Pricing
Enterprises obliged to prepare a transfer pricing file are also subject to annual reporting of the related-party transactions performed during the reported fiscal year. The deadline for annual reporting expires concurrently with the deadline for filing the annual corporate income tax return.

Greece has also enacted legislation introducing the automatic exchange of country-by-country reports, thus implementing Action 13 of BEPS. Country-by-country reporting obligations apply to multinational enterprise groups with an annual consolidated turnover exceeding EUR 750 million.

Special Tax Regimes

Shipping Companies
Shipping companies (local or foreign) enjoy a special tax regime based on L. 27/75, commonly known as the L. 89/67 shipping regime. Specifically, the profits of companies established under the regime are exempted from taxation provided that they are subject to tonnage tax, either for vessels under the Greek flag or foreign flagged vessels managed by a Greek ship management office established under the beneficiary regime of article 25 of L. 27/75.

Law 89 Offices for Commercial and Industrial Companies
The Commercial Law 89 Special Tax Regime is designed for entities providing specific back-office services to other entities of the same group. Under the sui generis tax scheme, a foreign entity may establish a local office which may exclusively provide supporting services to its associated companies such as consulting services, accounting support, quality review of the production of products and services, drafting studies, designs and contracts, advertising and marketing services, data processing, and research and development services. Recently, the permitted types of services were expanded to include software development, computer programming, IT systems support, information filing, storage and logistics management, supply chain management, and HR and call centre-related activities.
The regime provides certainty for the corporate tax base, since any expense which is properly recorded in the Greek books is treated as tax deductible, while all non-Greek employees employed by such an office are taxable in Greece on their Greek source income only, leaving any other source of income (i.e., foreign capital gains, rents sourced abroad, etc.) practically tax-free in Greece. Additionally, offices falling under the regime do not have to prepare transfer pricing documentation for their intra group transactions.

Family Offices
Individuals who are tax residents in Greece can manage their wealth and family assets through family offices established in Greece set up as legal entities of a type acknowledged in the country, such as Societé Anonyme, Private Capital Company, Limited Liability Company, etc.
The exclusive object of the family offices is to provide supporting services to high-net-worth Greek tax resident individuals and their close family members (such as their spouse, underage children, parents) for the management and administration of their assets and investments held directly or indirectly through legal entities.

Anti-Avoidance Rules
Greece has adopted all anti-avoidance rules and recently modified its Income Tax Code to align its legislation with the EU Anti-Tax Avoidance Directive (ATAD II).
In particular, the Income Tax Code provides specific anti avoidance rules on interest limitation (thin capitalisation), controlled foreign corporations (CFC rules), exit taxation and general anti-avoidance rules (GAAR).

Other anti-abuse rules
As an anti-avoidance rule, the carrying forward of tax losses is not permitted if:
During the tax year, the direct or indirect participation or the voting rights in a legal entity are amended to exceeding 33% and during the same tax year following the change of participation/voting rights, the entity’s business activity is changed and exceeds 50% of its turnover in relation to the previous tax year.

Statute of Limitations
As a general principle there is a standard five-year statute of limitations, which can be extended for one year in cases where new data or information from any source is brought to the attention of the tax authorities during the fifth year of the statute of limitations period.
However, from 2018 onwards, the statute of limitations period can be extended to ten years if no tax return has been filed and new data or hidden incomes are brought to the attention of the tax authorities, provided that the information could not have been brought to their attention within the five-year statutory limitation period.

A. Individual Tax Summary

Residence – Individuals are considered Greek tax residents if the following conditions are met:

  • Their habitual abode is in Greece; this comes about if the individual is physically present in Greece for more than 183 days in any 12-month-period. Certain exceptions are applicable for individuals visiting Greece for medical, tourist or similar private purposes and staying in Greece for more than 183 days but less than 365 days in a twelve month-period.
  • The centre of their vital personal and financial interests is in Greece.

Basis of Taxation – Individuals who have their tax residence in Greece are taxed on their worldwide income. Non-residents are taxed on their Greek source income only.

Filing Status – Taxpayers shall declare all taxable and exempt income in an annual tax return which must be filed by 30 June of the year following the relevant calendar year.
Filing in of joint tax returns by married taxpayers is permitted, though all types of income are taxed separately.

Taxable Income:

Employment and Pension Income

Greek tax residents are subject to income tax on income derived from employment. This includes the income from salaries, wages, allowances, pensions, stock-based compensation, and any other payments in cash or in kind for services rendered.
Salary, pension, freelancer, and personal agricultural income is taxed according to the following progressive tax rate scale:

Taxable income (EUR) Tax rate
(%)
Tax due
(EUR)
Cumulative
tax due (EUR)
0 – 10,000 9 900 900
10,001 – 20,000 22 2,200 3,100
20,001 – 30,000 28 28,800 5,900
30,001 – 40,000 36 3,600 9,500
40,001 and above 44

Business Income
Freelancer and sole proprietorship (individual businesses) income is also taxed according to the above progressive tax rate scale.

Passive Income

  • Dividends are subject to a 5% withholding tax rate except for foreign dividends received by a Greek tax resident which may be subject to a more favourable withholding tax rate based on an applicable double tax treaty.
  • Interest is subject to a 15% tax rate.
  • Royalties are subject to a 20% withholding tax rate.

Income from Capital Gains
Capital gains arising from capital alienation are taxed at a rate of 15%. In the case of the transfer of listed shares, the capital gains tax is imposed only if the following criteria are met cumulatively:

  • The acquisition date for the listed shares or listed securities is set after 1 January 2009.
  • The transferor holds at least a 0.5% participation percentage in the share capital of the company.

Income from capital gains may be exempt from tax in the case of the transfer of securities under the condition that the transferor is a tax resident of a country with which Greece has concluded a double tax treaty.

Alternative Tax Regimes for Non-Residents:
As of 2021, special alternative tax regimes have been introduced into the Greek Income Tax Code for high-net-worth individuals (Art. 5A L. 4172/2013), for individuals with foreign-source pension income (Art. 5B L. 4172/2013) and individuals repatriating in Greece earning employment and business income in Greece (Art. 5C L. 4172/2013), who choose to transfer their tax residence in Greece and apply to be subject to these tax regimes.

Special allowances for angel investors-individuals who invest in start-ups.
Individuals who are investing to start ups are entitled to a special deduction from their taxable income equal to 50% of the contributing capital.
The maximum amount that the angel investors can deduct from their taxable income per tax year, comes to €300,000 if the investor chooses to contribute the maximum investment amount of €100,000 to 3 different startups.

Special Solidarity Contribution
Beyond the income tax imposed on net incomes earned by individuals, a special solidarity contribution applies to all incomes earned on or after 01 January 2016 as follows:

Next 25,00044–Next 25,00044–

Taxable income (EUR) Tax rate
(%)
Tax due
(EUR)
Cumulative
tax due (EUR)
First 12,000 0.00 0 0
Next 8,000 2.2 176 176
Next 10,000 5.0 500 676
Next 10,000 6.5 650 1,326
Next 25,000 7.5 1,875 3,201
Next 155,000 9.0 13,950 17,151
Above 220,000 10.0

In an effort to remove the austerity measures adopted during the financial crisis, and especially for the tax year 2020, Greece has abolished the special solidarity contribution for all types of income other than employment income and income from pensions.

Furthermore, especially for the tax year 2021, the special solidarity contribution is abolished for income from employment in the private sector while currently the exemption expanded to include all other incomes earned from private individuals like rents, business profits, capital gains, dividends etc. Currently, several alternatives are being elaborated by the Independent Authority for Revenues so that such contributions can be completely abolished.

B. Sales and Other Taxes

Value Added Tax (VAT)
VAT is the most common indirect tax and is applicable to all supplies of goods and services.

The following rates currently apply:

Standard rate: 24%
Reduced rate: 13%
Super reduced rate: 6%

The VAT rates on the Aegean islands of Leros, Lesbos, Kos, Samos and Chios are 30% lower than the corresponding rates on the mainland:

Standard rate: 17%

Reduced rate: 9%
Super reduced rate: 4%

Taxable Transactions:

  • Supply of goods or services made in Greece by a person subject to tax
  • Reverse-charge for EU services received by a person subject to tax in Greece
  • Intra-community acquisition of goods from another European Union (EU) Member State by a person subject to tax
  • Importation of goods and certain services from outside the EU, regardless of the status of the importer.

For VAT purposes, the territory of Greece excludes Mount Athos.

Stamp Duty (Transactional Tax)
Stamp duty ranges from 1.2% to 3.6% and usually applies to transactions such as loans, assignment of debts etc., excluding bank loans.

Capital Accumulation Tax 1%
Applies to capital injections and capital increases of legal entities.

Annual Real Estate Tax (ENFIA)
ENFIA is calculated based on the deemed value of real estate properties, with the rate depending on the territory and the zone of the real estate, its area, construction year, whether the property is surrounded by a national road, and other factors.

Special Real Estate Tax: (SRET)
SRET is applicable at a rate of 15% imposed on a property’s deemed value in cases where legal entities hold real estate and do not disclose their ultimate beneficial owners.
Certain exemptions are applicable for companies with listed shares, or in the case of disclosure of the entire corporate ultimate beneficial owners’ structure.

Real Estate Transfer Tax
Real estate transfer tax is applicable upon purchase of real estate properties not subject to VAT. The rate is currently 3%, excluding premises that will be used for primary residence under specific conditions.

Last update: 04.08.2021

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Partner in Greece
Dimitrios Leventakis
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