top of page

Transfer Pricing Scheme in Greece

  • Tax Experts
  • Jun 5
  • 1 min read

August 25, 2017


This article explores the key developments and regulations surrounding Transfer Pricing scheme (TP) in Greece, with a specific focus on Cryptocurrency Taxation in the US and Europe, offering insights into how international tax rules are applied to digital assets in various regions.


The first formal application of Transfer Pricing (TP) rules in Greece was introduced under Article 26 of Law 3728/2008. Initially, the Ministry of Commerce was the competent authority, and written or oral agreements exceeding €200,000 were subject to scrutiny to ensure compliance with the Arm’s Length Principle.


Key Developments:


  • With the enactment of Law 4110/2013, Articles 39, 39A, 39B, and 39C of the Income Tax Code were amended, transferring TP supervision and audits to the Ministry of Finance.

  • Thresholds were lowered:

    • €100,000 for intra-group transactions by companies with turnover up to €5 million.

    • €200,000 for larger companies.


Continued Framework under Law 4172/2013:


The new Income Tax Code (L. 4172/2013) incorporated the OECD Transfer Pricing Guidelines into national legislation. While thresholds remained stable, several Circulars were issued to clarify compliance obligations:

  • Circulars 1097/2014, amended by 1144/2014, 1142/2015, and 1227/2015.

  • Requirements included:

    • Electronic submission of a Summary Table of Controlled Transactions.

    • Detailed Master File content requirements.


Benchmarking Analysis by TaxExperts


TaxExperts offers benchmarking analysis for controlled transactions, ensuring alignment with both Greek law and OECD guidelines.


Services Include:

  • Use of THOMSON REUTERS and ONESOURCE Transfer Pricing databases.

    • These platforms are internationally recognized and used by listed companies, auditors, and tax professionals.

  • Industry-specific analysis using financial data from independent companies.

  • Application of filters to exclude controlled or loss-making companies, ensuring arm’s length compliance.


 

 
 
bottom of page