The Greek tax authorities issued circular no. POL 1142/02.07.2015 dated July 2, 2015 to explain transfer pricing (TP) documentation issues raised in light of the new Income Tax Law no. L. 4172/2013 and Tax Procedures Code no. L. 4174/2013. The clarification was based on those transfer pricing issues that affect intercompany transactions pertaining to fiscal years starting from 1 January 2014 onward. The clarification is based on the concept of associated persons; the calculation of the interquartile range; the use of databases for the comparable company search; and the benchmarking studies to be used for documentation purposes.
It was also clarified that a foreign legal person or entity acquiring income in Greece from the exploitation of immovable property is subject to transfer pricing documentation requirements under the Greek legislation even if no permanent establishment exists in Greece.
