Greece
Corporate taxes and other direct taxes
Α flat corporate income tax rate of 22% is applied to resident corporations for fiscal years 2021 onwards. Non-resident corporations are taxed in Greece on any income generated in Greece. The relative tax rate applies after the deduction of business costs, depreciations, and provisions for bad debts. Major tax adjustments and non-deductible items include payments out of the banking system, transfer pricing adjustments, personal consumption expenditure, bad debts without legal actions, payments to low tax rate jurisdictions, non-paid SSC, and thin cap interests, to the extent that they are over 30% of EBITDA and EUR 3 million. Greek corporations are also subject to annual business tax up to EUR 1,000, irrespective of their profitability. Greek companies are subject to tax prepayment equal to 80% of the tax corresponding to the revenues of the tax year for which the return is filed. For newly established companies, the prepayment is reduced to 50% for the first three years of operations.
As of January 1, 2021, the withholding tax rate for dividends distribution is reduced to 5% for both individuals and the shareholders of legal entities. Interest payment is subject to a tax rate of 15% and the corresponding rate for royalties is 20%. Greece has incorporated 57 treaties on the avoidance of double taxation. If a DTT is applicable, the above-listed rates can be reduced. With the adoption of the EU Parent Subsidiary Directive, under certain conditions there is no withholding tax on dividends, interests, and royalties paid on EU (including Greece) intragroup transactions.
A real estate property tax applies in cases of immovable property ownership, while legal entities holding real estate located in Greece may be additionally charged with the 15% Special Estate Tax imposed on the objective value of the property if the beneficial owner or the individual shareholder is not known to the Greek authorities. A list of exemptions is provided under certain conditions. Capital gains from shares and immovable property are taxed as normal business profits (22%) for corporations and at a flat rate of 15% for individuals. For individuals, the 15% for capital gains arising from the sale of immovable property has been postponed until December 31, 2024.
| Transfer pricing in Greece |
| Arm's length principle |
 |
Since 1994 |
| Documentation liability |
|
Since 2008 |
| APA |
|
Since 2014 |
| Country-by-Country liability |
|
Since 2016
|
| Master file-local file (OECD BEPS 13) applicable |
|
Since 2015 |
| Penalty |
|
For non-submision of the country-by-country report, a fine of twenty thousand (20,000) euros is imposed and in case of late submission or submission of an inaccurate country-by-country report, a fine of ten thousand (10,000) euros is imposed. |
| - lack of documentation |
|
1‰ of TP transactions (€500-2,000) for inaccuracy/incompleteness. The penalty is imposed for the late submission of the Summary Information Table only when the total amount of transactions to be verified is altered and the difference > €200,000.
|
| - tax shortage |
|
For non-submission, a fine of 1‰ of TP transactions (min EUR 2,500, max. EUR 10,000) is applied. A penalty up to EUR 20,000 can be imposed for a missing documentation file. |
| Related parties |
> 33% |
Direct or indirect control or management dependence or exercise of decisive influence.
|
| Safe harbors |
 |
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Level of attention paid by Tax Authority:
VAT and other indirect taxes
The standard VAT rate in Greece is 24%, while the reduced rate is 13% (e.g. for agricultural services, accommodation services, certain types of foodstuffs) and 6% (e.g. journals, books, medicines, supply of electricity and gas). VAT-exempt activities include financial and banking services, insurance, medical services, and education (subject to certain conditions). Pursuant to the provisions of Art. 53 par. of Law 5073/2023, reduced VAT rates were expanded to several products and services (non-alcohol beverages) until June 2024. Regarding cinema tickets and the transportation of individuals and their luggage, reduced VAT rates were expanded without time limitation.
As for other indirect taxes, Greece applies a flat stamp duty rate of 1.2%, 2.4%, or 3.6% to certain transactions outside the scope of VAT, such as non-residential rents, loans, etc.
| VAT options in Greece |
Applicable / limits |
| Distance selling |
EUR 10,000/year |
| Call-off stock |
|
| VAT group registration |
|
| Cash accounting - yearly amount in EUR (approx.)* |
Optional for small companies with a turnover of up to 2m |
| Import VAT deferment |
|
| Local reverse charge |
B2B sales for laptops, tablets, cell phones, and game consoles under conditions
|
| Option for taxation |
| - letting of real estate |
Optional on business rentals
|
| - supply of used real estate |
|
| VAT registration threshold* |
Not applicable for taxable persons. However, small businesses with a turnover up to €10,000 may be exempted from VAT registration. Also, the threshold is set at €10,000 for pan-EU digital services and goods as a part of OSS return.
|
Personal income tax / Social security system
Pursuant to domestic tax law, as taxable employment income is considered to be any remuneration received by an employee within an employment context including benefits in cash or in-kind, such as the private use of a company car, a cost-of-living allowance and other benefits over EUR 300 per fiscal year. In Greece, personal income tax is subject to a progressive tax rate ranging from 9% to 44%. Additionally, tax payable on employment income is reduced by a family tax allowance from EUR 777 to EUR 1,780 under certain conditions. For individuals, real estate income is taxed at a progressive rate of 15% to 45%.
Active incomes fall under the scope of the SSC system. The vast majority of Greek employees have been covered by the Social Insurance Institution known as E.F.K.A. since January 1, 2017. Social security contributions are calculated based on the actual salary of the employee. The applicable rates for full time employees are 22.29% for employers and 13.87% for employees. For part-timers, the rates are also the same effective as of January 1, 2023. Social security grants benefits in the case of unemployment, sickness, disability, retirement, and death. For calculation purposes, the upper limit of social security contributions is defined as a gross salary of EUR 7,373.53.
Wage related taxes
in Greece |
Minimum wage
|
Average wage
in private sector |
| |
in EUR |
|
in EUR |
|
| |
780 |
|
1,445 |
|
| Total wage cost* |
954 |
122% |
1,767 |
122% |
| Employer's social security contribution** |
174 |
22.29% |
322 |
22.29% |
| Gross salary |
780 |
100% |
1,445 |
100% |
| Personal income tax*** |
- |
- |
74 |
9%/22%/28%/36%/44% |
| Special Solidarity Contribution **** |
- |
- |
- |
- |
| Employees' contributions |
108 |
13.87% |
200 |
13.87% |
| Net salary |
672 |
86% |
1.171 |
81% |
* per payroll period (there are 14 payroll periods per year)
** most common social security contributions rate (for full timers) regarding usual employment properties.
*** a tax reduction is provided for the taxpayer based on the number of dependents in conjunction with the total taxable income
**** not applicable for 2023