Greece - Revised transfer pricing rules; new documentation measures 

Article 39 and 39A of Greece’s income tax law were repealed and replaced by new measures that include the following:

• The transfer pricing rules now apply to all intercompany transactions (not only with respect to the sale of goods and the provisions of services, but also with respect to loan agreements and transfers of shares, partnerships, and real estate—all of which must now be documented).
• The rules establishing the thresholds of transactions subject to transfer pricing have been amended.
• Greek companies must report and document all intercompany transactions, not just their cross-border transactions.
• There are new rules for the preparation, submission, and updating of the transfer pricing documentation file.
• There are new rules concerning when the transfer pricing documentation must be updated and what information must accompany it.
• Transfer pricing documentation must be submitted within 30 days of a request from the tax authorities.
• A new provision allows enterprises to enter into advance pricing agreements (APAs) relating to the pricing of specific future transactions with related companies, beginning 1 January 2014.
• The transfer pricing documentation file must be prepared before the issuance of the tax certificate and in any case within 50 days from the closing date of the taxpayers’ financial year. For financial year 2012, the deadline for the preparation of the transfer pricing documentation and for the submission of the summary information sheet is 10 May 2013.

Read a January 2013 report [PDF 137 KB] prepared by the KPMG member firm in Greece: New Tax Law “Income Tax Provisions, Issues Related To The Authorities of The Ministry of Finance and Other Regulations” and New Law Incorporating Various Legislative Provisions

Contact a tax professional with KPMG's Global Transfer Pricing Services.