Recently, major transfer pricing regulation changes have taken place in Greece.
A bill was approved on 29 August 2013 by the Greek Parliament to expand the deadline for disclosing to the tax authority the inter-company transactions within a group and to exclude from the documentation requirements transactions with affiliates less than a certain threshold.
The new Tax Procedures Code (circulated on July 2013 and effective from 1 January 2014), includes the likelihood of an APA (Advance Pricing Agreement) for agreeing with the tax authority in advance the methodology of TP (Transfer Pricing) to be used in set up the prices for cross-border inter-company transactions together with the critical assumptions under which such methodology will remain applicable.
Also, the Tax Procedures Code introduces a GAAR (General Anti-avoidance Rule) that makes the acknowledgment for tax purposes of contractual arrangements dependent, among other issues, on whether such arrangements make sense from a commercial viewpoint and whether they conform to the actual conduct of the parties and the effective risks allocation.
