On 14 May 2019, Greece published document No. Ε.2076, sets forth the provisions of article 38 of Law 4605/2019 (Official Gazette Issue A’ 52/1 April 2019) amending the provisions of Law 89/1967, to broaden the relevant framework and incentivize the creation of shared services centers in Greece. Following changes are includes by the new law:
- Software development, computer programming and IT support
- Storage and management of records and data
- Management of suppliers, customers and supply chain, excluding transportation by own means
- HR management and training of employees
- Computer-based call center and telephone information services
Provision of the above services does not constitute a place of effective management in Greece by the foreign company established in Greece or its affiliates.
However, the new regulation does not refer generally to the development of business activity in Greece, but rather to the specific services for which an operation permit has been granted, if apart from the provision of such services, the conditions of article 4 par. 4 of Law 4172/2013 are met, i.e., clear violation of the operation permit, Article 4 (4) of Law 4172/2002 shall apply, resulting in these companies (or their affiliated companies) being considered tax residents in Greece, based on the recent clarifications of the Independent Authority for Public Revenue.
