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Greece: Thin-cap, CFC, anti-avoidance rules in new law; VAT vouchers

Greece: Thin-cap, CFC, anti-avoidance rules in new law

Among the tax law changes included in tax legislation (Law 4607/2019) in Greece are anti-avoidance rules that generally align Greek tax law with the EU anti-tax avoidance directive (ATAD).


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These measures include changes to the Greek domestic tax rules concerning thin capitalization (that is, an interest limitation rule), a controlled foreign corporation (CFC) rule, and the general anti-avoidance rule. The new rules addressing tax avoidance apply with respect to income and expenses derived from tax years beginning on or after 1 January 2019.

  • Interest limitation rule: Excess borrowing costs will be deductible in the tax year incurred up to 30% of the taxpayer’s earnings before interest, tax, depreciation and amortization (EBITDA). If the excess borrowing costs exceed the 30% of EBITDA threshold, the taxpayer can fully deduct excess borrowing costs up to €3 million.
  • CFC rule: Taxable income of a controlled foreign company includes the non-distributed income derived from several categories of “passive income” (such as dividends, interest, royalties, leasing activity, insurance, banking, and financial activities)
  • GAAR: The tax administration will disregard an arrangement or a series of arrangements that were intended to obtain a tax advantage that defeats the objective or purpose of the tax law.

VAT provisions

Other measures aim to harmonize Greek value added tax (VAT) law with Directive (EU) 2016/1065, and the concept of a “single-purpose” and a “multiple-purpose” voucher is introduced as a means of consideration corresponding to the supply of goods or services. When the place of supply of goods or services and the amount of VAT due are known, the voucher is classified as "single-purpose voucher," and each transfer of such voucher is subject to VAT. Otherwise, the voucher is classified as “multiple-purpose voucher,” and VAT is due only on the actual supply of the sold goods or services, upon voucher redemption. The new provisions apply as of 1 January 2019.

Taxation of shipping companies

The new law also includes rules for “permanent taxation” of shipping companies (both domestic and foreign) unless the companies are involved in the management or operation of ships.

In addition, there is an updated permanent “contribution agreement” for Greece and the maritime community, according to which members of the maritime community agree to financially assist the Greek government by voluntarily paying a fixed percentage of 10% of the amounts imported to Greece and derived from dividend income of the ultimate shareholders, partners or actual beneficiaries of the shipowner companies under Greek or foreign flag vessels.

Ultimate beneficial owner register

Under new provisions, corporate and other entities having their registered office in Greece as well as those conducting a business activity that is taxed in Greece are required to maintain in their registered office a special register of their “ultimate beneficial owners.”

Read an April 2019 report prepared by the KPMG member firm in Greece

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