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Results: 4 Answers
Corporate Tax
1.
Basic framework
1.1
Is there a single tax regime or is the regime multi-level (eg, federal, state, city)?
 
Greece
A single tax regime.

For more information about this answer please contact: Xenofon Papayiannis from KLC Law
1.2
What taxes (and rates) apply to corporate entities which are tax resident in your jurisdiction?
 
Greece
Corporate tax is imposed on the total income of any company or legal entity (for credit institutions, see question 2.7). The applicable tax rate for 2019 is set at 28%. According to the law, this will be reduced in the following years as follows:

  • 2020 - 27%
  • 2021 - 26%; and
  • 2022 onwards - 25%.
For more information about this answer please contact: Xenofon Papayiannis from KLC Law
1.3
Is taxation based on revenue, profits, specific trade income, deemed profits or some other tax base?
 
Greece
Taxation is based on profits. Profits are calculated as total revenues less business expenses (including depreciation and amortisation, and provisions for bad debts). Any revenue derived by a company or legal entity is considered as stemming from business activities.

For more information about this answer please contact: Xenofon Papayiannis from KLC Law
1.4
Is there a different treatment based on the nature of the taxable income (eg, gains on assets as opposed to trading income or dividend income)?
 
Greece
There is no difference based on the nature of the taxable income, as all income of legal entities is deemed to be business income.

For more information about this answer please contact: Xenofon Papayiannis from KLC Law
1.5
Is the regime a worldwide or territorial regime, or a mixture?
 
Greece
Greek tax residents are subject to Greek income tax with respect to their worldwide income. Non-residents are subject to Greek income tax only with respect to their Greek-source income.

For more information about this answer please contact: Xenofon Papayiannis from KLC Law
1.6
Can losses be utilised and/or carried forward for tax purposes, and must these all be intra-jurisdiction (ie, foreign losses cannot be utilised domestically and vice versa)?
 
Greece
Tax losses may be carried forward for five years.

Losses from a foreign permanent establishment may be neither utilised nor carried forward. By way of exception, losses arising from a permanent establishment located in another EU/European Economic Area state may be utilised against the relevant year’s profits and/or carried forward for five years, as long as that country and Greece have entered into a double tax treaty that does not provide for an exemption in Greece of the permanent establishment’s profits. However, according to the administrative guidelines, such losses may be offset against Greek profits only once the foreign permanent establishment closes and as long as it was not possible to utilise them in the country of the permanent establishment.

For more information about this answer please contact: Xenofon Papayiannis from KLC Law
1.7
Is there a concept of beneficial ownership of taxable income or is it only the named or legal owner of the income that is taxed?
 
Greece
A distinction between legal and beneficial ownership does not exist under Greek law. Normally, the Greek tax authorities will look at the legal owner. However:

  • the potential application of anti-avoidance rules is not precluded; and
  • random references to the ‘beneficiary’ of the income in the Income Tax Code could be used as a basis to turn against the beneficial owner.
For more information about this answer please contact: Xenofon Papayiannis from KLC Law
1.8
Do the rates change depending on the income or balance-sheet size of the taxpayer?
 
Greece
No. The corporate tax rate is flat and applies irrespective of the balance-sheet size or the level of profits.

For more information about this answer please contact: Xenofon Papayiannis from KLC Law
1.9
Are entities other than companies subject to corporate taxes (eg, partnerships or trusts)?
 
Greece
All kinds of companies and legal entities are subject to corporate tax, including corporations, partnerships, cooperatives, trusts, associations and so on.

For more information about this answer please contact: Xenofon Papayiannis from KLC Law