Page 24 - CEE Tax Guide 2025

Greece

Forvis Mazars Accounting Tax
Single Member P.C.
14 Amfitheas Avenue, 17564,
Palaio Faliro, Athens – Greece
Phone: +30 2106993749
www.forvismazars.com/gr

Corporate taxes and other direct taxes to EUR 1,000 and must prepay 80% of next year’s
tax based on current income, reduced to 50% for the
Greece applies a flat corporate income tax rate first three years of operation for new businesses.
of 22% to resident corporations. Non-resident Dividends in Greece are subject to a 5% withholding
corporations are subject to taxation in Greece on tax. Interest payments are taxed at 15%, while
income earned within the country. The 22% tax royalties are subject to a 20% withholding
rate is applied to taxable income after deducting tax. Greece has implemented the EU Parent-
business expenses, depreciation, and provisions Subsidiary Directive, allowing for withholding tax
for bad debts. Notable tax adjustments and non- exemptions on dividends, interest, and royalties
deductible items include payments made outside in intragroup EU transactions, provided specific
the banking system, transfer pricing adjustments, conditions are met.
personal consumption expenditure, bad debts As of tax year 2025 and onwards, a CIT exemption
not subject to legal action, payments to low-tax in the taxation of intragroup dividends and the
jurisdictions, unpaid social security contributions, transfer of shares is also applicable in Greece when
and thin capitalization interest, where such the distributor or transferor is based on a country
interest exceeds 30% of EBITDA or EUR 3 million. outside the EU, to the extent that certain
Corporations also pay an annual business tax of up
conditions are met.
The Uniform Tax on Real Estate Property (ENFIA)
Transfer pricing in Greece applies to all real estate rights in Greece, including

Arm’s length principle Since 1994 ownership, usufruct, occupancy, and surface rights.
The principal tax ranges from EUR 2 to 16.20 per
Documentation liability Since 2008 square meter for buildings and EUR 0.0037 to 9.25

APA Since 2014 per square meter for land, depending on location
and use. Starting in 2025, individuals can receive a
Country-by-Country Since 2016 20% ENFIA reduction for insured residences valued
liability
up to EUR 500,000, or a 10% reduction for higher-
Master file-local file Since 2015 value properties, insured for at least three months
(OECD BEPS 13)
applicable in the previous year. Legal entities are subject
to a 5.5‰ supplementary tax on total property
Penalty value, reduced to 1‰ for self-used real estate. The

lack of documentation 1% transactions Special Tax on Real Estate Property (SRET) imposes
(EUR 500—2K) for a 15% tax on the objective value of properties, if
inaccuracy if Summary no exemption applies. Capital gains from the
Table late, total > EUR 200K.
sale of shares and real estate are taxed at 22% for
tax shortage Fine 1‰ transactions corporations, while for individuals, real estate capital
(EUR 2.5K—10K) for non-
submission; up to gains tax is suspended until December 31, 2026.
EUR 20K for missing doc.
VAT and other indirect taxes
Related parties 33% < Direct/indirect control,
management dependence,
or decisive influence. The standard VAT rate in Greece is 24%, with
a reduced 13% rate for basic products, live
Safe harbors No – animals, supplies for special needs, children’s car

Level of attention paid 10/10 seats, diapers, cyclists’ helmets, and services like
by Tax Authority accommodation, care services, and food outlets.

Central and Eastern European tax guide 2025 Forvis Mazars 24