Greece: corporate tax guide

What the tax system covers

Resident companies are generally within tax on worldwide profits. Actual management, the attribution of controlled foreign income and permanent-establishment exposure should be tested independently of any personal arrival incentive.

When a company becomes tax resident

Income Tax Code Article 4(3) treats a legal person or entity as Greek resident if established under Greek law, if its statutory seat is in Greece, or if effective management is in Greece during any part of the tax year. Article 4(4) examines daily administration, strategic decision-making, shareholder meetings, books and records, board or executive meetings and the residence of the directors or executives. The majority shareholders’ residence can be considered together with those facts. A founder running a foreign company from Greece therefore needs a company-level analysis independently of personal residence or a personal arrival incentive.

Rates and the tax base

22% ordinary corporate income tax. Ordinary corporate business-profit rate; special entities, incentives and international minimum-tax rules require separate review.

Outbound dividends, interest and royalties

Dividends: 5%. Domestic dividend withholding rate. Qualifying group/directive exemptions or treaty relief can apply; this is separate from tax on the distributing company’s profits.

Interest: 15%. Domestic interest withholding rate, subject to statutory exemptions and treaty relief. A recipient’s legal form, instrument and any Greek permanent establishment affect final taxation.

Royalties: 20%. Domestic royalty withholding rate. Qualifying directive or treaty relief can change the deduction; the broad statutory rights definition should be checked against the actual contract.

The business needs an independent Greek tax analysis

A personal arrival regime does not determine where a company is resident, where its services are performed or whether an overseas entity has a Greek permanent establishment. Examine actual strategic and daily management, signing authority, personnel and records. A founder working from Greece can affect those facts even without opening a registered branch. Salary, dividends and retained corporate profit are different tax layers.

AADE’s Article 66 CFC circular expressly concerns natural persons, legal persons and legal entities with qualifying controlled foreign companies. It is therefore inaccurate to describe Greece’s CFC framework as relevant only to corporate shareholders. The control, foreign-tax, income and exception conditions need their own calculation. A genuine overseas business should be supported by accounts and operational evidence; a foreign registered office alone does not settle attribution, residence or transfer-pricing questions.

Retained Greek assets can leave ongoing obligations

A nonresident may still need to report Greek-source rent, business receipts, work or other income. Retained property also requires its own ownership declarations and property-tax compliance. Do not close every administrative account merely because the residence-transfer request is approved. Arrange an appropriate contact and access to myAADE so notices and deadlines are not missed.

If keeping an investor residence permit, check continued investment ownership, insurance and renewal requirements. If seeking citizenship, a prolonged departure can affect the permanent residence and integration evidence even where the investment permission remains valid. Reconcile the final resident return with the first foreign return, retain evidence of tax paid and update financial institutions with the accurate tax-residence information.

The company has its own return and payment cycle

AADE describes the ordinary legal-person return as due by the last working day of the sixth month after the tax year-end, with separate rules for liquidation. The published form and instructions need to match the actual tax year. A personal Article 5A, 5B or 5C election does not submit this return or settle the company's payroll, withholding and accounting obligations.

CFC attribution: three tests and a geographic exception

The control, low-tax and income-composition tests are cumulative. The low-tax test uses the amount payable if the foreign operation were taxed under Greek law; a published foreign rate is not a sufficient substitute. The more-than-30% threshold concerns the statutory income categories, which include low-value related-party invoicing as well as familiar investment income. The resulting inclusion follows the taxpayer’s participation and the year in which the foreign entity’s accounting period ends.

The substantial-activity exception requires actual personnel, equipment, assets and premises supported by the facts. Article 66 excludes third countries outside the EEA from this exception: demonstrating an active business outside that geography does not, by itself, establish entitlement to it. AADE also expressly applies the relevant business-income tax treatment to natural persons or legal persons as appropriate. This is why a personal investor should not dismiss CFC analysis as a corporate-only issue.

Foreign tax credit is capped at the Greek tax attributable to the income. Maintain year-by-year records of previous inclusions because distributions and disposals receive adjustments for income already taxed. Foreign CFC losses are not simply deducted against the owner’s unrelated current income; the carry-forward conditions are distinct.

Exit-tax documentation and payment planning

Before moving assets or effective management, list the assets Greece will cease to tax, their tax bases and defensible market values. Article 66A permits specified valuation evidence: an independent valuation report, qualifying fair-value accounting records, or a transfer-pricing valuation. AADE’s audit instructions call for the relevant comparability analysis rather than automatically demanding the entire transfer-pricing file.

The evidence file also includes the tax-basis records and recent financial statements. Article 66A requires the exit declaration three working days before the relevant transfer, with payment on submission unless the instalment option applies. Eligible EU/EEA transfers can use five equal annual interest-free instalments; qualifying EEA cooperation conditions apply. The first instalment accompanies the declaration and the remaining four fall due by the last working day of the following four years.

A demonstrated collection risk can require security; AADE identifies a current-assets-to-total-liabilities ratio below one as relevant under Decision A.1231/2020. A subsequent disposal, move outside the qualifying area, insolvency or prolonged missed payment can accelerate the unpaid balance. Article 66A requires notification and payment within three working days for the specified disposal, onward-transfer and insolvency triggers. Instalments therefore require continuing monitoring after the original move.

Temporary transfers for securities financing, collateral, prudential capital or liquidity management have a restricted 12-month return exception and a declaration requirement. A zero declaration under that exception does not eliminate the need to monitor the return deadline and any required guarantee.

Foreign companies and income attribution

Article 66 can attribute specified undistributed foreign income to both individual and corporate taxpayers. The tests include more than 50% control alone or with associated enterprises, actual foreign tax below half the Greek-law counterfactual, and more than 30% of pre-tax net income in the specified categories. Those categories include interest, royalties, dividends/share disposals, financial leasing, financial activities and low-value related-party invoicing. A substantial economic activity exception exists, but does not extend to a CFC resident or established in a third country outside the EEA.

Departure, migration and continuing obligations

Article 66A applies to companies/entities and Greek permanent establishments transferring assets, tax residence or PE activity so that Greece loses relevant taxing rights. The charge is based on market value less tax value at exit, even without a sale. A residence move excludes assets that remain effectively connected to a Greek PE. Qualifying EU/EEA transfers can use five annual instalments under the statutory conditions; security and early-payment triggers require separate review.