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Tax Law

The “non-dom” tax regime: Alternative taxation of foreign-source income of individuals transferring their tax residence to Greece – Article 5A of the Greek Income Tax Code

Conditions for inclusion in the regime The provisions of article 5A of Law 4172/2013-Greek Income Tax Code (ITC) provide for an alternative tax regime, commonly known as the “non-dom regime”, according to which a taxpayer individual who transfers his or her tax residence to Greece can be taxed in an alternative manner for income generated abroad, in other words all income not generated in Greece, provided all the following conditions are met: a) he or she was not tax resident in Greece during 7 out of the previous 8 years prior to transfer of his or her tax residence to Greece, which...

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Taxation of dividends and bonuses from shipbroking and related companies

Following the amendments introduced with Law 5036/2023 regarding the taxation of dividends from shipbroking companies and related businesses as well as of the bonuses paid to the directors and personnel of these companies and of ship-management companies in Greece, the Greek Independent Authority for Public Revenue (IAPR) has issued Decision A. 1175/2023 which amends the former Decision A. 1223/2019 for the content of the relevant tax return for such income. In a nutshell: Dividends Dividends paid or credited, in accordance with the provisions of article 43 par. 5 of law, to an individual-Greek tax resident by: foreign companies of any type which have...

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Place of taxation for VAT purposes of services related to events

General rule for B2B services According to the provisions of Article 14 par. 2 a) of the VAT Code (Law 2859/2000), as in force from 01.01.2010, the supply of services to taxable persons acting as such is taxed, as a general rule, at the place of establishment of the recipient of the services (general B2B rule).   Admission to cultural, artistic, sporting, scientific, educational, entertainment and similar events granted to taxable persons. According to the provisions of Article 14 par. 8 of the VAT Code, as in force from 1.1.2011, admission to cultural, artistic, sporting, scientific, educational, entertainment and similar events which is...

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Appointment of Fiscal Representative for VAT purposes in Greece

Additional obligations for customs related obligations Acquisition of a Greek VAT number through the appointment of a Fiscal representative   The concept/requirement of a Fiscal Representative for VAT purposes The appointment of a Fiscal Representative for VAT purposes is provided by the Greek VAT legislation (Law 2859/2000-Greek VAT Code) and is actually a requirement (obligation) for cases where a company that is not established in Greece carries out activities in Greece that create VAT liabilities in Greece and for which the company must obtain a Greek VAT number in order to fulfil its compliance/reporting VAT obligations and pay the Greek VAT to the State. Among...

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Issuance of Greek tax number (AFM)

The Greek tax number (AFM) is a single and unique number assigned by the Tax Administration to an individual or legal person/legal entity, local or foreign, that is going to carry out business activities in Greece or become liable to pay tax or to submit any declaration in Greece [articles 10 and 11 of the Tax Procedure Code - Law 4987/2022]. The issuance of A.F.M. is carried out before the competent Tax Office online or in person.  Apart from the issuance of AFM, the issuance of personal tax codes (“kleidarithmos” in Greek) is required as well in order to receive access...

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Liability of directors of Greek companies for taxes and social security contributions

Α. tax obligations (Article 50 of Law 4987/2022) The individuals who are executive presidents, directors, general managers, administrators, managing directors, authorized to manage and liquidators of legal persons and legal entities, as well as the individuals who exercise the management or administration of a legal person or legal entity, are personally and jointly liable for the payment of income tax, withholding tax, any imputed tax, VAT and ENFIA, imposed to these legal persons and legal entities, regardless of the time of the tax assessment, as well as for interest, fines, surcharges and any administrative monetary sanctions imposed on them, as long...

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Greek tax treatment of interest payments made by a Greek company to a foreign lender company

According to the Greek tax legislation, any interest amount paid by a Greek company to an entity established abroad is subject to a withholding tax at a rate of 15%. The paid withholding tax exhausts the Greek tax liability in the event that the recipient of the above payment, which is subject to withholding tax, is a legal entity that does not have its tax residence and does not maintain a permanent establishment in Greece (par. 4 of article 37 and par. 3 of article 64 of Law 4172/2013, Circular POL.1042/2015). The above applies based on the domestic legislation and is...

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Brief overview of the Greek VAT regime

Main types of supplies subject to VAT in Greece The main types of supplies subject to VAT in Greece are, among others: a) the supply of goods and services carried out within Greece for consideration by a taxable person acting as such in the course of his business; b) the intra-Community acquisitions of goods in Greece for consideration by a taxable person acting in his capacity as such (or by a non-taxable legal entity on the condition that the supplier is subject to VAT in another EU Member State and the non-taxable acquirer has exceeded the IC threshold of Euro 10,000 annually). Especially,...

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Requirements and procedure for the establishment of an office/branch in Greece under article 25 of Law 27/1975

Foreign shipping companies interested in establishing an office or branch in Greece under the provisions of Article 25 of Law 27/1975, are required to submit the following documentation to the Directorate of Maritime Policy and Development of the Ministry of Maritime Affairs: a. An application including the name, type, registered office and nationality of the foreign management company as well as its activity and the specific activities of its office in Greece as well as its representative. The above application will also state that: The company undertakes the obligation to import into Greece an annual foreign exchange, not compulsorily assignable, or...

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Overview of the shipping tax regime in Greece

Tonnage Tax Regime The Greek tonnage tax regime has been established as a favorable system of taxation of shipping activities. This tax system enables ship owners to plan their business activity in the long term without increased tax burdens, while it also contributes to keeping the cost of operating ships at a competitive level. In general terms, according to the tax provisions of Law 27/1975, the tonnage tax is payable by shipowners or ship-owning companies of ships under Greek flag and exhausts the tax liability of the shipowner, as well as their ultimate shareholders, up to the level of the private...

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