On 23 September 2022, Greece published Law No. 4972/2022 in the Official Gazette containing various tax measures including transfer pricing. The law amends an existing provision on transfer pricing adjustments upwards to provide for corresponding downward adjustments. Accordingly, after an audit, the taxable profits of a Greek taxable entity are adjusted at arm’s length and if such profits have also been included in the taxable profits of a related entity, then that related entity may have requested a corresponding reduction. To do this, the affiliated legal entity must apply for the correction by submitting an amended tax return and delivery of the corresponding audit report.
The amended tax return and notification of the relevant audit report must be submitted within three months from the notification of adjustment for the first-mentioned legal entity. This measure is generally effective from 23 September 2022.
