Tax Law Archives - Iason Skouzos - TaxLaw

N.5313/2026: A New Tax Framework for carried interest and Alternative Investment Funds

Angeliki Spyridon — Mon, 05 Oct 2026 11:06:18 +0000

Law No. 5313/2026 (Government Gazette, Issue A, No. 102 of 25 June 2026) seeks to make Greece more attractive to teams managing alternative investments. The relevant provisions address three areas: they extend the favourable tax treatment of the additional return (carried interest) to a broader range of investment structures, restore the correct cross-reference in the provision governing Alternative Investment Funds (AIFs), and extend the favourable AIF regime to third-country funds and managers. The ultimate aim is to enable fund management to be carried out from Greece without creating a taxable presence (permanent establishment) in Greece for foreign funds, while offering...

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Tax treatment of a donation of bare ownership of immovable property with retention of usufruct

Angeliki Spyridon — Wed, 09 Sep 2026 13:21:20 +0000

With regard to usufruct of immovable property – that is, the real right of the usufructuary to use and enjoy another’s property whilst preserving its integrity – we note that it is non-transferable and extinguishes upon the death of the usufructuary. In the event that the heir acquires bare ownership of immovable property by notarial deed (such as a gift, parental gift or transfer for valuable consideration) whereby the usufruct is retained by the donor/transferor, and the donor/ usufructuary/transferor dies at a later date, bare ownership and usufruct are automatically merged, and the heir acquires the right to full ownership...

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Your Guide to Challenging Decisions of the Greek Tax Administration

Niki Plyta — Wed, 12 Aug 2026 07:46:09 +0000

Administrative appeal procedure Where a taxpayer disputes any decision issued against them by the Tax Administration, they must lodge an administrative appeal requesting a review of the decision within the framework of an administrative procedure by the Dispute Resolution Directorate (DED) of the Independent Authority for Public Revenue (IAPR), in accordance with the following procedure: The taxpayer submits the administrative appeal electronically via their Taxisnet account, together with the following documents: a) an application for suspension in the case of a standalone submission, The administrative appeal must be lodged with the tax authority that issued the decision within thirty (30)...

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When Can the Sale of Investment Assets Be Treated as Business Income in Greece?

Niki Plyta — Wed, 12 Aug 2026 07:16:00 +0000

The Greek Income Tax Code distinguishes between income derived from investment activities and income arising from the carrying on of a business. In certain circumstances, gains realised by individuals from the disposal of assets may be treated as business income rather than capital gains. This distinction can have significant tax implications, particularly where the assets disposed of do not fall within the categories of securities specifically covered by the capital gains provisions of the Income Tax Code. The Legal Framework Article 21 of the Greek Income Tax Code provides that a “business transaction” exists where a transaction is carried out...

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Greece Introduces Binding Tax Rulings

Niki Plyta — Tue, 11 Aug 2026 08:18:44 +0000

Law 5301/2026 marks one of the most important developments in Greek tax administration in recent years by introducing, for the first time, a formal Binding Tax Ruling (BTR) procedure. Alongside this innovation, the new legislation also reforms several provisions of the Code of Tax Procedure concerning tax penalties and cash payment restrictions. The new framework is expected to enhance legal certainty for taxpayers, particularly in complex domestic and cross-border transactions, while bringing Greece closer to the practices already followed in many other OECD and EU jurisdictions. Introduction of Binding Tax Rulings The centrepiece of the new legislation is the insertion of Article...

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Tax Treatment in Greece of Directors’ Fees Received from a Lithuanian Company

Angeliki Spyridon — Thu, 28 May 2026 09:07:47 +0000

Directors’ fees received by a Greek tax resident from participation on the board of directors of a Lithuanian company raise important cross-border tax considerations, both under the Double Tax Treaty (“DTT”) between Greece and Lithuania and under Greek domestic tax law. The analysis below assumes that the remuneration constitutes directors’ fees paid in consideration for duties performed in the capacity of a board member of the Lithuanian company, and that such remuneration does not relate to employment services or dividend distributions. Double Tax Treaty Between Greece and Lithuania The taxation of directors’ fees is governed by Article 16 of the...

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Taxation of withdrawals made by a Greek tax resident from a Self-Invested Personal Pension (SIPP) in the United Kingdom

Angeliki Spyridon — Tue, 07 Apr 2026 12:03:37 +0000

According to Articles 12(1) and (3), 14(1) and 15(4a) and (4b) of the Greek Income Tax Code: Gross income from employment and pensions includes all types of income in cash or in kind acquired in the context of an existing, past or future employment relationship. The following are considered gross income from pensions: pensions granted by the main and supplementary compulsory insurance institutions, as well as by professional funds established by law, and insurance paid as a lump sum or in the form of periodic benefits under group pension insurance contracts any other benefit received in respect of a past...

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Inheritance – Taxation of assets belonging to Greek citizens located in Greece and the United States

Angeliki Spyridon — Mon, 30 Mar 2026 13:48:39 +0000

According to Article 3 of the Code of Provisions on Inheritance Tax, Gifts, Parental Benefits and Winnings from Games of Chance (Law 2961/2001 – hereinafter referred to as the “Code”), inheritance tax in Greece is levied on: Any property of any kind located in Greece, whether owned by Greek nationals or foreigners. Tangible or intangible movable property located abroad belonging to Greek nationals residing anywhere, as well as to foreign nationals residing in Greece. With regard to the Convention between Greece and the USA (Legislative Decree 2734/1953, Government Gazette A’ 329/12.11.1953 – hereinafter “DTT”) for the avoidance of double...

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Taxation of director’s remuneration received by a Greek tax resident from the United Kingdom

Angeliki Spyridon — Mon, 30 Mar 2026 13:24:04 +0000

According to Articles 3, 5 and 15 of the Income Tax Code, natural persons who are tax residents in Greece are subject to tax on their taxable income derived from both Greece and abroad, i.e. on their worldwide income earned in a tax year. Income arising abroad is defined as any income that does not arise in Greece. Income from employment is considered to be of Greek origin when it is earned in Greece and of foreign origin when it is earned abroad. Income from employment is taxed in Greece according to the following scale: ...

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Taxation of dividends received by a Greek tax resident from the United Kingdom

Angeliki Spyridon — Mon, 30 Mar 2026 13:15:16 +0000

According to the general rules of Greek law, based on Articles 9, 36 and 40 of the Income Tax Code: If, during the tax year, a taxpayer – natural person who is a tax resident in Greece – earns income abroad, the income tax payable by that taxpayer in respect of that income is reduced by the amount of tax paid abroad on that income. The payment of the tax abroad is proven by the relevant supporting documents. The reduction in income tax provided for may not exceed the amount of tax corresponding to this income in Greece. The term...

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