Greece: local rules

Greece applies the arm's length principle in article 50 of the Income Tax Code (ITC, Law 4172/2013). If related persons deal on terms that independent parties would not use, the profit that was not made because of those terms is added to the taxable profit (art. 50(1)). The rule is applied and read in line with the OECD principles and guidelines (art. 50(2)). Article 51 covers the transfer of functions. The documentation rules are in the Tax Procedure Code (TPC, Law 5104/2024, which replaced Law 4987/2022 and before that Law 4174/2013), art. 25. Advance pricing is in art. 26 TPC.

Related persons with dealings under art. 50 ITC, or transfers of functions under art. 51, must keep a Documentation File of a master file and a Greek file (art. 25(1) TPC). They are exempt if the dealings total up to EUR 100,000 a year and turnover is up to EUR 5m, or total up to EUR 200,000 and turnover is above EUR 5m (art. 25(2)). The files must be ready by the end of the corporate income tax return deadline, and a Summary Information Table is filed electronically in the same deadline (art. 25(3)). The file is kept at the registered seat and handed over within 30 days of a request (art. 25(4)). Its content is set by decision POL.1097/2014 (Government Gazette B' 883/2014) as amended by POL.1144/2014 (B' 1374/2014).

POL.1097/2014 lists the comparable uncontrolled price, resale price, cost plus, transactional net margin and profit split methods. The traditional methods are preferred, and the transactional methods may be used with reasons if comparable data is missing. Internal and external comparables are allowed, and any database may be used if it is named in the file. The arm's length range is the interquartile range: the lowest and highest 25% of values are dropped, and any value from the 25th to the 75th percentile is accepted with adequate justification. The decision points to the OECD Guidelines as updated from time to time.

A late or inaccurate Summary Information Table is fined 1/1000 of the covered dealings, from EUR 500 to EUR 2,000, and a missing one from EUR 2,500 to EUR 10,000 (art. 55(1)(a) and (b) TPC). If the Documentation File is handed over on days 31 to 60 after a request the fine is EUR 5,000, on days 61 to 90 it is EUR 10,000, and later or never it is EUR 20,000 (art. 55(1)(c)). A transfer pricing adjustment also carries the inaccurate return fine of 10%, 25% or 50% of the extra tax, depending on its size (art. 54 TPC). A missing CbC report is fined EUR 20,000, and a late or inaccurate one EUR 10,000 (art. 56(1)(a)). A late return with no tax due is fined EUR 100, and a late tax return otherwise EUR 250 or EUR 500, depending on the bookkeeping system (art. 53(1) and (2), as amended by Law 5301/2026). The same art. 53 fines apply to late or missing Pillar Two returns and notices (A.1131/2026, A.1055/2026).

Law 5100/2024 (Government Gazette A' 49) applies EU Directive 2022/2523 to Greek entities of groups with revenue of at least EUR 750m in two of the four prior years (art. 3). The IIR and the domestic top-up tax apply to fiscal years starting on or after 31 December 2023, and the UTPR (arts. 13 to 15) to years starting on or after 31 December 2024 (art. 69). The GIR is filed with the AADE within 15 months of year end, or 18 months for the transitional year (art. 48(7)). If it is filed abroad instead, the Greek entity files a notification naming the filer by the same date (art. 48(4); decision A.1055/2026). The top-up tax return is due by the last working day of the month after the GIR month, and the tax is paid in one payment by the last working day of the month after that (art. 49). For year ends up to 31 March 2025, AADE decision A.1131/2026 moved the GIR and the notification to 30 October 2026, and the AADE FAQ moved the top-up tax return to 30 November 2026.

Groups with consolidated revenue of at least EUR 750m file the CbC report within 12 months of year end (art. 9AA Law 4170/2013), and every Greek entity notifies the AADE by the last day of the reporting year (art. 4 Law 4490/2017). Under art. 7(1) TPC, a deadline set by tax law that falls on a Saturday, Sunday or public holiday moves to the next day the tax office is open, so the tool rolls weekend and holiday dates forward. Deadlines set as a 'last working day' are listed as exact dates instead. Greek Orthodox Easter moves each year, so Good Friday, Easter Monday and Holy Spirit Monday change with it (Good Friday is 30 April 2027). Greece also has the DAC6 mandatory disclosure rules (art. 9AB Law 4170/2013) and advance pricing agreements (art. 26 TPC, unilateral decisions within 18 months, valid up to 4 years). The corporate return has been extended by AADE decision in recent years, with 24 July 2026 the latest.