A foreign tax credit may be available for Greece’s “special solidarity contributions” on foreign-sourced income under certain existing income tax treaties.
Circular C.2147/2019 provides that the Greek special solidarity contribution is considered to be a tax similar to an income tax, for which a foreign tax credit is available under certain income tax treaties (a list of eligible treaties is provided in an addendum to Circular C.2147/2019).
The circular includes credit or refund procedures, and provides that taxpayers can submit amended tax returns with a notation “FOR FOREIGN TAX CREDIT PURPOSES” for their tax returns to be re-assessed. Amended tax returns and claims for refunds of special contribution payments must be submitted (in hardcopy) to the appropriate tax office.
A claim for foreign tax credits relating to special solidarity contributions can be made for tax years 2015 and later years, if not already set off with the initial assessment of the tax return, by the last business day of 2019. The circular clarifies that the tax credit cannot exceed any outstanding amount of non-offset foreign income tax.
Read an August 2019 report prepared by the KPMG member in Greece
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