The most important development that took place with regard to Greece’s transfer pricing regime was the enactment of Law 4337/2015 and inclusion of revised transfer pricing penalty in adjustment in new law. As per Law 4337/2015, additional tax between 5% and 20% of the tax amount resulting from transfer pricing adjustment on the basis of the initial tax return may trigger penalty of 10% on the difference and additional tax greater than 20% but less than 50% of the tax amount resulting from transfer pricing adjustment give rise to penalty of 25% on the difference. If additional tax is greater than 50% of the tax amount resulting from transfer pricing adjustment on the basis of initial tax return then the penalty will rise to 50% on the difference.
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