On 18 May 2021, the Government Officially published Law 4799/2021, introducing income tax reductions and other amendments to the Greek Income Tax Code. The Act includes some of the following provisions:

Transfer pricing

Enterprises obliged to prepare a transfer pricing file are subject to annual reporting of the related-party transactions performed during the reported fiscal year. The deadline for annual reporting is due simultaneously with the deadline for filing the annual corporate income tax return. On the other hand, Greece has also enacted legislation introducing the automatic exchange of CbC reports, thus implementing Action 13 of BEPS. The MNE groups with an annual consolidated turnover exceeding EUR 750 million are subject to CbC reporting obligations.

Statute of Limitations

As a general principle there is a standard five-year statute of limitations, which can be extended for one year in cases where new data or information from any source is brought to the attention of the tax authorities during the fifth year of the statute of limitations period.

Corporate income tax

Corporate income tax (CIT) rate is reduced to 22% from 2021 onwards. The prepayment is assessed based on the CIT return of tax years 2020 onwards. The rate of income tax down payment for legal persons and legal entities is reduced from 100% to 80% for the income tax returns of the tax years 2021 onwards.

WHT payments

Intra-group payments for dividends, interest and royalties received by other EU parent entities are exempted from withholding taxes, given that the legal entity making the payments and the recipient qualify under the conditions set by Directive 2011/96/EU and Directive 2003/49/EU. In the case of a non-EU parent entity and/or when the parent company does not qualify for the participation exemption rule, the provisions of double tax treaties will be applicable and prevail over Greek tax law.

Incentive on industry/manufacturing

The Income Tax Code specifies that specific expenses are non-deductible under certain conditions, while special rules apply to super deductions for research and development expenses (R&D).

Loss treatment

Greece has adopted the stand-alone approach for corporate groups and does not provide any legislation for group taxation. Offsetting tax losses incurred abroad against business profits derived in Greece is not permitted, with the exception of income arising in other EU or EEA member states which is non-exempt according to the applicable double tax treaties. Losses may be carried forward for a maximum of 5 years.