Transfer Pricing regulations are stated in Articles 39 and 39A of L. 2238/1994.

Transfer Pricing provisions were initially introduced in Greece, in a simplified form, in 1980. Conversely, Transfer Pricing regulations were not commonly considered by the tax authorities until 2008.

On September 23, 2022, Greece published Law No. 4972/2022 in the Official Gazette containing several tax measures, including Transfer Pricing. The law amends an existing provision concerning the upward Transfer Pricing adjustments to provide for corresponding downward adjustments.

Related Parties

A related party is defined as:

  • The equity stake of a person in the capital stock of another person through direct or indirect ownership of shares or any other equity stake of at least 33% in terms of value, number, profit-sharing rights, or voting rights of these shares;
  • The relationship with any other person who directly or indirectly owns shares, equity stakes, voting rights, or any other ownership interest rights of at least 33% in terms of value, number, profit sharing rights, or voting rights of the shares of any other related entity;

The relationship with any other party with which there is a substantial direct or indirect administrative relationship, in which there is dependence or control, or any other party that exercises or may exercise decisive influence with respect to the decision-making of an entity, as well as common control, dependence, or influence of a third party.

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 Author:       Wolfgang Hartl
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