The Greece Ministry of Finance has enacted legislation Bill 5162/2024 on 5 December 2024 which introduces a participation exemption regime for intra-group dividends and capital gains received by Greek tax-resident legal entities from non-EU entities.
Earlier, The Greek Ministry of Finance (MoF) 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.
