Greece: no expense deduction if companies do not comply with transfer pricing rules
Any payments to affiliated companies that do not comply with Greece’s transfer pricing documentation requirements before the relevant transaction is carried out are not deductible.
Only if the local taxpayer can provide conclusive evidence that they complied with local transfer pricing documentation requirement before a regular audit tax place, may avoid non deductibility.
It is clear that this measure is also part of a package to increase local tax revenues and to counter tax evasion. Nevertheless, this measure may hurt also regular tax payers. Therefore, we recommend to review whether your transfer pricing documentation in relation to Greece is still adequate.back to overview