MAZARS CERTIFIED PUBLIC
130 Syngrou Avenue,
176 71 Athens, Greece
International Tax / VAT
The corporate income tax is proportional in Greece. The tax base, i.e. the pre-tax profit modified by several increasing as well as decreasing items, is taxed at the rate of 29%. Additionally, a withholding tax of 15% is imposed on the after-tax dividends paid (for individual shareholders, this withholding tax exhausts the tax liability for the specific income); a lower rate may apply under an applicable tax treaty and no withholding tax applies if the conditions of the EU parent-subsidiary directive are met. In Greece, losses can be carried forward within a period of five fiscal years; the carrying back of losses is not permitted. Special limitations are applicable in case of M&A transactions.
Greece applies thin capitalization (based on surplus interest expenses), Anti-hybrid and CFC rules. In Greece, there is a wide range of tax allowances for new investments, R&D and shipping.
Apart from dividends, there is also a withholding tax on interest earned and royalties. As regards consulting, technical and administrative services provided to a Greek company by a foreign company in Greece no withholding tax is imposed regardless if the service is provided by the foreign company or its Greek branch. Furthermore, Greece has a wide international treaty network with more than 55 double tax treaties, which can be implemented for declining the withholding tax rates applicable to income of all the above kinds earned by non-resident companies.
Regarding real estate taxation, there are two basic regulations. There is a principal and a supplementary annual capital tax imposed on real estate assets. For buildings, the principal tax may vary basically from EUR 2.00 to 13.00 per square meter, according to the size, location, age, usage and other characteristics of the property. The supplementary tax is imposed on the total value of the real estate owned, at an average rate of 0.55%. Finally, there is an annual special tax of 15% on the nominal tax value of real estate assets located in Greece for legal entities that do not wish to declare their individual shareholders. (However, a wide list of exemptions is provided, including shipping companies with an establishment in Greece, firms with capital share structured on nominal shares, firms with other business revenue in Greece that is higher than their real estate revenue in Greece, firms owned or controlled by the Greek public sector.)
|Transfer pricing in Greece|
|Arm’s length principle||since 1994|
|Documentation liability||since 2008|
|Hyerarchy in TP methods||Follows OECD TP Guidelines|
|Lack of documentation||For inaccuracy/incompleteness;
1‰ of TP transactions (min EUR 500-EUR 2,000)
|Tax shortage||For non submission , fine of 1‰ of TP transactions (min EUR 2,500 max. EUR 10,000).|
|direct or indirect control or management dependence or exercise of decisive influence|
Level of attention paid by Tax Authority:
The general rate is 24% and the reduced rates are 13% (e.g. food, electricity, water supply) and 6% (e.g. books, medicines,). The options/limits based on the EU Directive:
VAT-exempt services are mainly banking services, insurance, investment-related services, the sale of real estate under certain conditions (the rental of real estate may be either subject to VAT 24% or exempted, according to the common will of the two related parties), certain services provided by medical doctors and dentists, certain types of education and training, and certain other activities which are tax exempt with regard to their public interest nature or their special character.
Other indirect tax types in Greece are stamp duty, excise duty (on energy, tobacco and alcohol products), financial transactional tax, tariffs, sale taxes (on video lottery terminal games), local business tax (restaurant and related services, advertising expenses).
|VAT options in Greece||Applicable / limits|
|Distance selling||EUR 35,000/year|
|VAT group registration|
|Cash accounting||Optional for small companies up to 2m turnover|
|Import VAT deferment|
|Local reverse charge||sale of waste|
|Option for taxation|
|- letting of real estate||optional on business rents|
|- supply of used real estate||No|
|VAT registration threshold||EUR 10,000/year|
The PIT is progressive in Greece. There is a different income tax rate per source of income (employees, pensioners, sole proprietorships-freelancers, real estate and securities income), and a reduction on the taxable income is granted depending on the income and the children only for employees and pensioners. The tax rate applicable to employees, pensioners, business activities and freelancers consists of four income brackets (EUR 0 to 20,000: 22%; EUR 20,001 to 30,000: 29%; EUR 30,001 to 40,000: 37% income above EUR 40,001: 45% tax rate applies. Employment incomes fall under the scope of the SSC system: individual social contributions equal altogether 16.00%; employer’s contribution is altogether 25.06%.
Starting from 2017 a new SSC system (EFKA) is applicable for free lancers, members of the BoD, shareholders etc. The calculation basis of the EFKA contributions is the taxable income and the rate varies to 26,95%-37,95%.
Benefits in kind are also considered as employment income and taxed accordingly. SSC are also applicable. The examples below show the cost of the employer and the employee in case of minimum wage level and the average wage in the private sector.
Finally, a Special Solidarity Contribution has been imposed to income earned by individuals. The rates of such solidarity contributions are as follows: 2,2% for total income from EUR 12,001 to EUR 20,000, 5% for total income from EUR 20,001 to EUR 30,000, 6,5% for total income from EUR 30,001 to EUR 40,000, 7,5% for total income from EUR 40,001 to EUR 65,000, 9% for total income from EUR 65,001 to EUR 220,000 and 10% for income higher than EUR 220,000.
|Wage-related taxes in Greece||Minimum wage||Average wage in private sector|
|in EUR||in EUR|
|Total wage cost||733||125,06%||1 554||125,06%|
|Employer's social security contribution||147||25,06%||311||25,06%|
|GROSS SALARY*||586||100%||1 243||100%|
|Personal income tax*||-||22%/29%/ 37%/45%||97||22%/29%/ 37%/45%|
* per payroll period (there are 14 payroll periods per year)