Special topics Archives - Iason Skouzos - TaxLaw

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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Closure of a Branch of a Foreign Commercial Company in Greece

Angeliki Spyridon — Fri, 04 Sep 2026 13:49:20 +0000

In recent years, it has become increasingly common for foreign commercial companies to establish branches in Greece in order to carry out all or part of their activities in the country. The branch of the foreign company is managed by its legal representative, who is appointed by the foreign company, hereinafter referred to as the “mother company”. The decision concerning the appointment of the legal representative is notified to the General Commercial Registry, hereinafter referred to as the “G.E.M.I.”. In the event that the “mother company” or the foreign branch itself wishes to cease the branch’s activities and, consequently, close...

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The Schengen 90/180-Day Rule: Why Travelers Are Getting Flagged at the Border — and What to Do About It

Angeliki Spyridon — Thu, 03 Sep 2026 09:19:19 +0000

Non-EU nationals travelling to Greece and the wider Schengen Area are subject to a well-known but frequently misunderstood limit: 90 days of stay within any rolling 180-day period. In practice, we are seeing a growing number of travelers stopped or questioned at the border because of how this rule is calculated — and because of how the EU’s new digital tracking system handles it. It’s a Rolling Window, Not a Calendar Count The 90/180 rule does not reset on fixed dates. Every day a traveler is present in the Schengen Area counts toward the limit, and the 180-day “look-back”...

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Articles of Association of a Greek Société Anonyme: Mandatory Content and Room for Customisation

Niki Plyta — Fri, 14 Aug 2026 09:03:39 +0000

The incorporation of a Société Anonyme (AE) in Greece requires the drafting of Articles of Association, which must include certain elements expressly required by law, while at the same time leaving the founders considerable room to shape the company’s operation according to their own needs. This article sets out in detail both the minimum mandatory content of a company’s Articles of Association and the main optional provisions that may be incorporated into them, should the founders wish to do so. Minimum mandatory content Every set of Articles of Association of an AE must, at a minimum, identify the founding members...

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Single-Member Société Anonyme: Additional Obligations Compared to the Ordinary S.A.

Niki Plyta — Fri, 14 Aug 2026 08:50:28 +0000

A single-member (sole-shareholder) Société Anonyme (S.A.) is a special form of S.A. in which the entire share capital belongs to just one person, whether natural or legal. While it is generally subject to the same general legislative framework as an S.A. with multiple shareholders (Law 4548/2018), the law provides for certain additional publicity and documentation formalities, aimed at preventing abuse of the legal entity or sham transactions between the sole shareholder and the company. 1. Registration of single-shareholder status with the General Commercial Registry (G.E.MI.) The company must appear in its publicity records as a “Single-Member Société Anonyme” or “Sole-Shareholder...

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The Inheritance Contract under the New Greek Inheritance Law

Niki Plyta — Fri, 14 Aug 2026 08:38:01 +0000

One of the most significant innovations of the new Greek inheritance law is the introduction of the inheritance contract mortis causa, an institution that has not, until now, been recognized under Greek law. For the first time, the person whose estate is at issue is given the ability to regulate their succession by contract, without this doing away with the fundamental principle of freedom of disposition. The inheritance contract is a standalone institution, distinct from a will, and is governed by specific rules as regards its formation, its binding effect, and its relationship with other testamentary dispositions. Article 1798 of...

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Validity of Wills under the New Greek Inheritance Law

Niki Plyta — Wed, 12 Aug 2026 08:23:38 +0000

A comparative review of the provisions governing the validity of wills shows that no substantial changes have been introduced between the previous and the new Greek inheritance law. The most significant change concerns the broadening of the concept of a testamentary disposition, which now covers not only wills but also inheritance contracts. Otherwise, the rules governing the validity of wills remain essentially unchanged. The drafting or revocation of a will before the new inheritance law enters into force, i.e. before 16 September 2026, continues to be governed, as regards form and the testator’s capacity, by the law previously in force,...

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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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