The Greek Ministry of Finance (MoF) has initiated a public consultation regarding the introduction of a participation exemption for intra-group dividends and capital gains derived from non-EU entities. This proposed measure aims to enhance the attractiveness of Greece as a location for multinational corporations by providing tax benefits.

The exemption shall be applicable if the distributing entity fulfils several cumulative conditions for intra-group dividends: It must be classified as a capital company according to the laws of its country of residence; it should not be situated in a non-cooperative jurisdiction or one lacking an administrative tax assistance agreement; it must be subject to corporate income tax or a similar tax without the option for exemption; the Greek tax-resident entity must hold a minimum of 10% participation in the value, share capital, or voting rights of the distributing entity; and this minimum participation must be maintained for at least 24 months.

The consultation is set to conclude on 19 November 2024.

The law seeks to strengthen income and the resilience of the economy by the establishment of new, and modification of existing, regulations regarding the provision of tax incentives for research, development, and the enhancement of innovation and start-up businesses. Other objectives include the enhancement of investments in start-up businesses by providing residence permits to investors from third countries; updating and unification in a single text of the tax treatment of corporate transformations regulated by Law 4601/2019 (A’ 44) and the transformations of other businesses; modernisation of the institutional framework governing the Independent Authority for Public Revenue; and updating of the legislative framework governing the submission of income tax returns.