· 8 min read

Greece – Transfer Pricing (2025)

Greece incorporates the Arm’s Length Principle into domestic law. The Income Tax Code (L.4172/2013) contains transfer pricing provisions, notably Article 50, and specifies that these rules are applied and interpreted consistently with the OECD Transfer Pricing Guidelines. The Greek domestic law provides a definition of related parties in Article 2, Section g of the Income Tax Code (L.4172/2013, Article 2, Section g). The term “Associated person” covers any person who participates directly or indirectly in the management, control or capital of another person; in particular, persons holding directly or indirectly thirty-three percent (33%) or more of shares, voting rights or profit rights are considered associated, as well as situations of substantial management dependency or decisive influence.

Arm’s Length Principle and the role of the OECD Guidelines

The OECD Transfer Pricing Guidelines are expressly used as an interpretative source in Greece. Domestic administrative decisions refer directly to the OECD Guidelines, and the OECD TPG are followed in Mutual Agreement Procedures (MAPs) and Advance Pricing Agreements (APAs). The administrative framework explicitly references the OECD principles when setting out methods, comparability analysis and documentation requirements (Decision No POL. 1097/9.4.2014, as in force).

Greece’s statutory definition of related parties is set out in the Income Tax Code (L.4172/2013, Article 2, Section g) under “Associated person”. The law treats as associated persons any entity with direct or indirect participation in management, control or capital of another. The statute explicitly captures ownership of thirty-three percent (33%) or more by value or number, profit or voting rights; collective situations where one person owns at least 33% of another entity; and relationships of substantial management dependency, control or potential decisive influence. Permanent establishments (PEs) are considered in relation to profit attribution rules, and domestic law follows the Authorised OECD Approach (AOA) where applicable under domestic law and treaty provisions.

Methods and application criteria

Administrative Decision No POL. 1097/9.4.2014 (as in force) establishes a preference for traditional transaction methods—the Comparable Uncontrolled Price (CUP), Resale Price Method and Cost Plus Method—considered the most direct means to test whether conditions between associated enterprises reflect market conditions. Transactional profit methods, such as the Transactional Net Margin Method (TNMM) and Profit Split, are acceptable where traditional methods cannot be applied reliably, for example due to lack or limits on reliable comparable data. Method selection is fact-specific and follows the “most appropriate method” standard rather than a strict hierarchical application (Decision No POL. 1097/9.4.2014).

Comparability and ranges

Greece follows the comparability analysis described in Chapter III of the OECD Transfer Pricing Guidelines and has domestic administrative guidance on comparability (Decision No POL. 1097/9.4.2014 and Decision No POL. 1142/2.7.2015). The tax administration does not prefer domestic comparables over foreign ones and does not use secret comparables. Domestic rules permit the use of an arm’s length range and statistical measures to determine arm’s length remuneration, consistent with the Administrative Decisions cited. While the regulations do not categorically require comparability adjustments in all cases, they acknowledge that adjustments may be necessary in specific circumstances to account for material differences between the compared situations (Decision No POL. 1097/9.4.2014).

Documentation and reporting

Greek law requires transfer pricing documentation consisting of a Master File, a Local File and a Country-by-Country Report (CbCR), consistent with Annexes I, II and III of Chapter V of the OECD Guidelines. In addition, taxpayers must prepare and electronically submit a Summary Information Table containing group-level information, functional and risk profiles, and a short description of the transfer pricing method chosen (Tax Procedure Code (L.4174/2013, Article 21); Decision No POL. 1097/9.4.2014; Decision No POL. 1142/2.7.2015; L.4484/2017; Law 4490/2017; Decision No POL. 1184/22.11.2017; Decision No POL. 1341/2019).

The TP Documentation File must be prepared by the filing deadline for income tax returns. The Summary Information Table should be submitted electronically within the same deadline. Documentation must be held at the taxpayer’s headquarters for the statutory retention period for books and records and must be made available to the tax administration within thirty (30) days of a formal request. The Master File for foreign groups may be kept in an internationally accepted language, preferably English, but must be translated into Greek upon request by the tax authority within a reasonable timeframe and no more than thirty (30) days from receipt of the request. In all other cases TP documentation should be maintained in Greek. The CbCR relevant to a fiscal year must be submitted to the tax administration no later than twelve (12) months after the last day of the relevant fiscal year; constituent entity notifications about the identity of the Reporting Entity must be submitted by the last day of the relevant fiscal year.

Safe harbours / exemptions / materiality

Greece does not maintain general safe harbour rules for specific industries, taxpayers or transaction types. Exemptions from documentation obligations are provided by quantitative thresholds: taxpayers whose intra-group transactions or transfers of operations do not exceed EUR 100,000 per tax year are exempt when their turnover does not exceed EUR 5 million; taxpayers with intra-group transactions not exceeding EUR 200,000 per tax year are exempt when their turnover exceeds EUR 5 million. Legal entities exempt from taxation under the Income Tax Code are not required to document transactions with affiliates. Natural persons, including sole traders, are not required to prepare transfer pricing documentation (Tax Procedure Code (L.4174/2013, Article 21); Decision No POL. 1142/2.7.2015).

APAs and MAP; procedures and timing

Greece offers Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs) as mechanisms to prevent and resolve transfer pricing disputes. The domestic framework allows for unilateral, bilateral and multilateral APAs and contains administrative provisions regulating their processing (Tax Procedure Code (L.4174/2013, Article 22); Decision No POL. 1284/31.12.2013; Decision No POL. 1129/30.8.2017; Decision No POL. 1226/6.10.2020). For detailed procedural timelines and MAP profile information, the OECD MAP profile for Greece is the appropriate source.

Penalties and other considerations

Greek law establishes a graduated penalty regime for transfer pricing documentation and CbCR non-compliance. For late filing, inaccurate or incomplete filing of the Summary Information Table, a fine equal to one thousandth (1/1000) of the transactions subject to documentation is imposed, with a minimum of EUR 500 and a maximum of EUR 2 000. Where the Summary Information Table is not filed, the fine is 1/1000 of the transactions with a minimum of EUR 2 500 and a maximum of EUR 10 000. Late filing of an amended Summary Information Table incurs a fine only if changes in amounts exceed EUR 200 000. Inaccurate filing results in fines calculated on the amounts concerned only if the inaccuracy exceeds 10% of the total transactions subject to documentation.

If the TP Documentation File is provided between the 31st and the 60th day after notification, the fine is EUR 5 000; if provided between the 61st and the 90th day, the fine is EUR 10 000; if not provided at all or provided after the 90th day, the fine is EUR 20 000. Repeat violations within five years result in doubled fines; further repetitions lead to fines quadruple the original amount. Failure to file the CbCR triggers a EUR 20 000 penalty; late or inaccurate/incomplete CbCR filing carries a EUR 10 000 penalty (Tax Procedure Code (L.4174/2013, Article 56); Decision No POL. 1252/20.11.2015; L.4484/2017).

Adjustments and other administrative treatments

Greece allows year-end adjustments when they lead to an arm’s length outcome. The jurisdiction does not generally implement secondary adjustments as a standard practice (the administrative position indicates secondary adjustments are not applied). Re-characterisation and other substantive adjustments are governed by domestic law and administrative practice, and are interpreted in light of OECD guidance; the treatment of PEs will depend on domestic law and the wording of applicable tax treaties.

Attribution of profits to permanent establishments

Domestic law follows the Authorised OECD Approach (AOA) for attributing profits to permanent establishments. However, there are at present no tax treaties in force that include the new version of Article 7 of the OECD Model Tax Convention; for treaties that do not contain the updated article, Greece will apply the profit attribution rules laid out in the relevant treaty rather than the AOA.

Conclusion

Greece’s transfer pricing regime is anchored in the Income Tax Code and a set of administrative decisions that explicitly align domestic practice with the OECD Transfer Pricing Guidelines. The system favors traditional transaction methods where reliable comparables exist but permits transactional profit methods where these are more appropriate. Documentation requirements are comprehensive and enforcement includes substantive monetary penalties for non-compliance. Preventive and dispute resolution mechanisms such as APAs and MAPs are available. Where domestic law is silent or non-specific, OECD guidance serves as the primary interpretative reference.

References

This summary is based on the OECD country profile for Greece and the cited national laws and administrative decisions. For access to the OECD repository of transfer pricing country profiles see https://www.oecd.org/en/topics/sub-issues/transfer-pricing/transfer-pricing-country-profiles.html

Share:
Back to OECD
Disclaimer:

La información presentada en este perfil se ha generado tomando como base datos y contenidos publicados por la OCDE. Si bien se busca reflejar fielmente la información disponible, no se garantiza su exactitud ni exhaustividad y se recomienda consultar las fuentes originales de la OCDE para fines oficiales o de investigación.