The following requirements relative to financial services and Advance Pricing Agreement (APA) are described below:
Financial Services:
Financial services must follow the arm’s length principle. It should also be noted that interest is deductible only to the level that the net interest does not exceed 25% of the incomes before interest, tax, depreciation and amortization. Any additional interest may however be carried forward for up to 5 years. If a company is not part of a group and the net interest is less than EUR 1 million per year then the interest is however deductible in full.
Advance Pricing Agreement (APA)
Under Tax Procedures Code and Decree of 31 December 2013, some requirements are included on Advance Pricing Agreement. An APA application may be prepared in relation to cross-border intra-group transactions in financial years from 1 January 2014 onwards. Applications may be made for a unilateral APA with the Directorate of Tax Audits. An informal initial consultation may be requested with the tax office. The APA request may contain a request for competent authority negotiation for the conclusion of a bilateral APA involving another country with which Greece has concluded a double tax treaty.
