Transfer Pricing Scheme in Greece

The first application of Transfer Pricing rules was introduced by the art. 26 of L. 3728/2008. The competent authority was the Ministry of Commerce and written or oral agreements over €200,000 were checked regarding the compliance in accordance with the Arm’s Length Principle. After the publication of the L.4110 / 2013, which amended Articles 39, 39A, 39B and 39C of Income Tax Code, the Transfer Pricing supervision and auditing were taken over by the Ministry of Finance. In addition, the thresholds declined to €100,000 for intra-group transactions of companies with turnover up to €5.000.000, and €200,000 for intra-group transactions of companies with higher turnover.

The threshold and the overall manipulation of Transfer Pricing did not change significantly after the adoption of the new Income Tax Code (L. 4172/2013), which integrated the OECD’s Transfer Pricing Guidelines in the national Law. In the context of the application of the new Tax Code, several Circulars were released regarding the electronic submission of a summary table including controlled transactions and the content of the Transfer Pricing Master File (see Circulars 1097/2014 – as amended by 1144/2014, 1142/2015 and 1227/2015).


Benchmarking Analysis by TaxExperts

TaxExperts may undertake the benchmarking analysis of your controlled transactions using comparable financial data from independent companies which are included in the same industry. More specifically:

  • TaxExperts has access to the THOMSON REUTERS database and to the specialized platform ONESOURCE TRANSFER PRICING. This platform is used by many listed companies, accountants and auditing firms and considered as one of the best databases in the world.


TaxExperts undertakes the benchmarking analysis in accordance with the provisions of the Greek legislation and OECD Guidelines, rejecting controlled and loss-making companies.

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