Greece Tax Regime

Greece operates a classical corporate income tax system at a standard 22% rate (29% for credit institutions that have elected into the deferred tax assets regime), layered with a distinctive tonnage tax regime for shipping that exhausts the tax liability of ship owners and, in most cases, replaces ordinary corporate income tax and dividend withholding tax entirely for qualifying maritime activity. As an EU and eurozone member state, Greece's regime is shaped heavily by EU directives — the Parent-Subsidiary, Interest-Royalties and Anti-Tax-Avoidance Directives — and by the OECD/EU Pillar Two global minimum tax, transposed into Greek law by Law 5100/2024. The Income Tax Code (Law 4172/2013, as amended) and the Tax Procedures Code (Law 4987/2022) form the backbone of the regime, administered by the Independent Authority for Public Revenue (AADE).

1.1 Sources

Primary legislation includes the Income Tax Code (Law 4172/2013), the Tax Procedures Code (Law 4987/2022), the VAT Code (Law 2859/2000), Law 27/1975 and Law 4336/2015 governing shipping taxation, and Law 5100/2024 transposing the EU Pillar Two directive.

1.2 Recent developments

Greece's standard corporate income tax rate has remained at 22% into 2026 following the reduction from 24% in earlier years, with credit institutions electing into the deferred tax assets (DTA) regime under Article 27A of the Income Tax Code continuing to bear a higher 29% rate. Law 5100/2024 incorporated the EU Pillar Two directive (Council Directive 2022/2523) into Greek legislation, introducing an income inclusion rule, undertaxed profits rule and qualified domestic minimum top-up tax for in-scope multinational and large-scale domestic groups. The tonnage tax regime for shipping continues to apply broadly to Greek- and foreign-flagged vessels managed from Greece, following earlier EU State Aid clearance, with the regime's scope confirmed as extending to bareboat charterers, lessees and their ultimate beneficial owners since 1 January 2020.

Headline statutory corporate income tax rate for a resident company. Where sub-national (state, provincial, cantonal or municipal) corporate taxes apply, the combined rate reported by the OECD is shown. Projected 2026–2028 rates carry the current rate forward unless a change is already enacted or officially scheduled. As-of 2026.

Top marginal statutory personal income tax rate on employment income for a resident individual. Where sub-national (state, provincial, cantonal or municipal) income taxes are a standard part of the system, the combined top rate is shown. Projected 2026–2028 rates carry the current rate forward unless a change is already enacted or officially scheduled. As-of 2026.

2.1 Rates and residence

Legal entities that are tax resident in Greece — having their registered seat or place of effective management in Greece — are subject to corporate income tax on worldwide income at a standard flat rate of 22%, excluding credit institutions. Credit institutions that have elected to participate in the deferred tax assets (DTA) regime under Article 27A of the Income Tax Code are instead subject to CIT at 29%. Non-resident companies are taxed on Greek-source income, in particular income attributable to a Greek permanent establishment. There are no municipal or local income taxes in Greece, so the headline national rate represents the full corporate tax burden on ordinary trading profits.

2.2 Shipping and the tonnage tax regime

Greece applies a distinctive tonnage tax regime to Greek-flagged vessels and to foreign-flagged vessels managed by a ship management office maintained in Greece under Law 27/1975, covering category 'A' vessels (cargo vessels, tankers, passenger vessels, drilling platforms and similar) and category 'B' vessels (small boats and other motor vessels). Tonnage tax is computed by applying coefficient rates to bands of gross registered tonnage and an age-correction factor, with exemptions including a six-year exemption for vessels built in Greek shipyards under a Greek flag and a 50% reduction for vessels on regular routes to or between Greek and foreign ports. Since Law 4336/2015, the tonnage regime has been expanded to vessels flying EU or EEA member state flags to align treatment following an EU discrimination challenge. Tonnage tax exhausts the income tax liability of the ship owner (and, where the owner is a company, its shareholders) in respect of operating profits and capital gains on disposal of the vessel; no CIT or dividend withholding tax applies to qualifying shipping profits. An annual contribution, calculated on imported foreign exchange at a scale of 7% up to USD 200,000 and 6% on the excess (subject to prescribed annual minimums), is separately imposed on ship management, chartering, insurance, average-settlement and brokerage offices under Law 27/1975.

2.3 Dividends and participation exemption

Dividends received by a Greek company from another Greek company, or from an EU subsidiary in which it holds at least 10% of the capital for an uninterrupted period of at least 24 months, are generally exempt under the Parent-Subsidiary Directive as implemented domestically. Capital gains on the disposal of qualifying EU participations meeting the same holding and threshold conditions are likewise exempt. Dividends from non-EU subsidiaries or from participations that do not meet the exemption conditions are subject to CIT at the standard rate, with credit relief for underlying and withholding tax suffered abroad under domestic law or applicable tax treaties.

2.4 Income determination and deductions

Taxable income is computed from the statutory accounts prepared under Greek accounting standards or IFRS, adjusted for tax rules. Business expenses are deductible where incurred for the purpose of generating taxable income, are properly documented and reflect real transactions at arm's length; certain items, including specific entertainment and non-business-related expenses, are non-deductible or subject to caps. Depreciation follows fixed statutory rates by asset category (buildings, machinery, vehicles, intangibles), generally on a straight-line basis, with accelerated rates available for qualifying green and digital-transition investments under recent incentive legislation. Goodwill arising on business acquisitions is amortised over a prescribed period for tax purposes where recognised.

2.5 Interest limitation

Consistent with the EU Anti-Tax-Avoidance Directive, Greece limits the deductibility of net borrowing costs to 30% of tax EBITDA, subject to a de minimis safe harbour for smaller net interest amounts and an equity-ratio escape clause for entities that are part of a consolidated group. Denied interest may generally be carried forward for deduction in future years, and unused interest capacity may likewise be carried forward, subject to the statutory carryforward period. Standalone entities without associated enterprises or foreign permanent establishments are excluded from the limitation.

2.6 Losses

Tax losses may generally be carried forward for five years to offset future taxable profits; there is no loss carryback. Loss carryforwards can be forfeited where there is a substantial change in the ownership or activity of the loss-making company that indicates the change is undertaken principally to obtain a tax advantage, consistent with general anti-avoidance principles applied by the tax authority.

2.7 Group taxation

Greece does not operate a formal fiscal consolidation or group relief regime allowing the pooling of profits and losses across separate legal entities; each Greek company is assessed to corporate income tax on a standalone basis. Groups with multiple Greek entities must therefore manage intra-group pricing, financing and loss positions with the absence of consolidation in mind, typically through mergers, restructurings or careful transfer pricing rather than statutory group relief.

2.8 Controlled foreign companies

Greece applies ATAD-based CFC rules attributing the undistributed passive income (interest, royalties, dividends, income from financial leasing, insurance and banking activities, and income from invoicing companies with limited economic substance) of a low-taxed controlled foreign entity to the Greek parent, where the foreign entity's effective tax rate is below 50% of the tax that would have been paid in Greece, the entity's passive income exceeds specified thresholds, and the entity does not carry on substantive economic activity supported by staff, equipment, assets and premises commensurate with its activities.

2.9 Transfer pricing

Greece follows the OECD Transfer Pricing Guidelines, requiring related-party transactions to be conducted on arm's-length terms. Domestic legislation mandates transfer pricing documentation (a Greek-specific 'Summary Information Table' and supporting documentation file) for related-party transactions above prescribed materiality thresholds, together with country-by-country reporting for constituent entities of groups with consolidated revenue of EUR 750 million or more, consistent with EU and OECD BEPS Action 13 standards. Advance pricing agreements are available, allowing taxpayers to agree transfer pricing methodologies with AADE in advance for a fixed period.

2.10 Incentives

Greece offers a range of investment incentives under its development laws, including tax exemptions, accelerated depreciation, and cash grants for qualifying investment plans in priority sectors such as manufacturing, tourism, energy transition, digital transformation and research and development. A patent box-style reduced taxation applies to qualifying income from intellectual property developed through Greek R&D activity, and super-deductions are available for qualifying R&D expenditure and green/digital capital investment. Strategic investment status under the fast-track licensing framework provides additional administrative and fiscal support for large qualifying projects.

2.11 Pillar Two

Law 5100/2024 transposed the EU Pillar Two directive (Council Directive 2022/2523) into Greek law, applying to multinational and large-scale domestic groups with consolidated revenue of at least EUR 750 million in at least two of the preceding four fiscal years. The regime secures a 15% effective minimum tax through an income inclusion rule, an undertaxed profits rule, and a qualified domestic minimum top-up tax (QDMTT) that takes priority over foreign top-up mechanisms for Greek-located low-taxed profits. Transitional CbCR-based safe harbours are available for the initial years of application, and in-scope groups face standalone registration and minimum tax return filing obligations in Greece even where safe harbours reduce the top-up amount to zero.

2.12 Branch income and reorganisations

A Greek branch of a foreign company is taxed at the standard 22% CIT rate on profits attributable to the branch under the authorised OECD approach; there is no separate branch profits or remittance tax. Domestic and EU cross-border reorganisations — mergers, demergers, contributions of assets and share exchanges — can generally be effected on a tax-neutral basis under Greek legislation implementing the EU Merger Directive, preserving book values and loss carryforwards subject to conditions, provided the arrangement has valid commercial reasons and is not undertaken principally to obtain a tax advantage.

3.1 Residence and rates

Individuals are tax resident in Greece if they have their permanent or main residence, habitual abode, or the centre of their vital interests in Greece, or are present in Greece for more than 183 days in a 12-month period. Residents are taxed on worldwide income; non-residents on Greek-source income only. Employment and pension income is taxed at progressive rates for 2026 ranging from 9% on the first EUR 10,000 up to 44% on income above EUR 60,000, with intermediate brackets of 20% (EUR 10,000–20,000), 26% (EUR 20,000–30,000), 34% (EUR 30,000–40,000) and a new 39% band on income from EUR 40,000 to EUR 60,000. Business income of individuals (sole proprietors) is taxed under a similar progressive scale, with a business-specific solidarity-style surcharge having been phased out in recent years for most income categories.

3.2 Capital income and real estate

Dividends are taxed at a flat 5% withholding rate, which is generally final for individuals. Interest income is subject to a flat 15% withholding tax, and capital gains on the disposal of listed and unlisted securities are generally taxed at 15%, subject to specific exemptions for certain shareholdings. Rental income from real estate is taxed at progressive rates of 15%, 25%, 35% and 45% depending on the amount of annual rental income (a new 25% band on income between EUR 12,000 and EUR 24,000 applies from 2026), reflecting Greece's continued use of real estate income as a distinct progressive schedule rather than a flat rate. A special solidarity contribution has been substantially phased out for most income types in recent tax years.

3.3 Social security and payroll

Employees and employers contribute to the unified social security fund (EFKA), with employee contributions of roughly 14–16% of gross salary and employer contributions of roughly 22–25%, subject to caps and variations by sector and employment category. Wage tax is withheld monthly by the employer under the PAYE-style system and reconciled through the employee's annual tax return. Self-employed individuals pay social security contributions calculated on a notional or actual income basis depending on their registration category.

3.4 Inbound individuals

Greece has introduced several regimes to attract inbound individuals, including a favourable flat-tax regime for foreign pensioners relocating tax residence to Greece (7% flat tax on foreign-source pension income for a fixed number of years), a non-domicile-style regime for high-net-worth individuals investing a minimum amount in Greece (an annual flat tax on foreign-source income), and a 50% reduction of taxable employment or business income for qualifying individuals transferring their tax residence to Greece under the digital nomad and expatriate relocation incentives. There is no general net wealth tax, though the Single Property Tax (ENFIA) is levied annually on real estate ownership, and inheritance and gift tax apply at progressive rates depending on the relationship between donor/deceased and recipient.

Greece applies domestic withholding tax on dividends at 5%, on interest at 15%, and on royalties and certain technical/consulting fees paid to non-residents at 20%, subject to reduction or elimination under the EU Parent-Subsidiary and Interest-Royalties Directives for qualifying intra-EU payments meeting minimum shareholding and holding-period thresholds. Greece's extensive treaty network of more than 55 double tax treaties frequently reduces these rates further, particularly for dividends (commonly 5–15%) and royalties (commonly 5–10%). Payments connected with tonnage-tax-qualifying shipping activity are generally outside the ordinary withholding framework given the exhaustive nature of the tonnage tax.

Relief at source for intra-EU dividend, interest and royalty flows requires beneficial-ownership and substance documentation; absent such documentation, tax is withheld at the domestic rate with refund available on application. Treaty relief is subject to the principal-purpose test following Greece's ratification of the OECD/G20 multilateral instrument, and AADE scrutinises the substance of intermediate holding structures before granting directive or treaty benefits on outbound payments.

5.1 General anti-abuse and hybrids

Greece applies a general anti-abuse rule denying tax benefits from arrangements or series of arrangements put in place with the main purpose of obtaining a tax advantage that defeats the object of the applicable tax law, consistent with the EU ATAD GAAR. Hybrid mismatch rules neutralise deduction/non-inclusion and double-deduction outcomes arising from hybrid financial instruments, hybrid entities and permanent establishment mismatches involving related parties or structured arrangements, whether within the EU or with third countries.

5.2 Exit taxation and disclosure

Exit taxation applies where a Greek company transfers assets, its tax residence, or the business carried on through a permanent establishment out of Greece, taxing unrealised gains at the point of transfer, with instalment payment over five years available for transfers within the EU/EEA. Greece has implemented DAC6 mandatory disclosure rules requiring intermediaries and taxpayers to report reportable cross-border arrangements bearing prescribed hallmarks, and DAC7 platform reporting obligations for digital platform operators, alongside public country-by-country reporting for large multinational groups under the EU directive as transposed domestically.

6.1 VAT

VAT is levied at a standard rate of 24%, with reduced rates of 13% (certain food, water supply, hotel accommodation, and other specified goods and services) and 6% (books, newspapers, pharmaceuticals and certain medical products). Reduced VAT rates apply on several Aegean islands to reflect their remoteness, subject to periodic government review. Registration is required for taxable persons exceeding turnover thresholds, and small businesses below the threshold may benefit from a simplified regime. VAT returns are generally filed monthly or quarterly depending on accounting basis, with an annual VAT clearing statement in certain cases; input VAT is recoverable for taxable business activities subject to standard EU-derived deduction and adjustment rules.

6.2 Transaction, property and other taxes

Real estate transfer tax applies at 3% on the value of most property transfers, alongside stamp duty on specified legal documents and transactions not subject to VAT. The Single Property Tax (ENFIA) is levied annually on the ownership of real estate at rates depending on location, size, use and age of the property, comprising a principal tax plus a supplementary tax for higher-value property portfolios. Inheritance and gift tax apply at progressive rates ranging from 1% to 40% depending on the degree of kinship between the parties and the value transferred, with more favourable brackets for close relatives. Excise duties apply to fuel, tobacco and alcohol, and a luxury living tax and motor vehicle taxes complete the indirect tax landscape. There is no general net wealth tax beyond ENFIA on real estate.

7.1 Filing, assessment and audit

The tax year is generally the calendar year, though legal entities keeping double-entry books may adopt a fiscal year ending 30 June, provided the tax year does not exceed twelve months. Corporate income tax returns are filed electronically with AADE, generally by the last day of the sixth month following the end of the tax year, with advance tax payments (generally 80% of the current year's assessed liability for most corporations) collected alongside the return and credited against the following year's final liability. Audits are risk-based and increasingly data-driven, drawing on AADE's electronic invoicing and real-time transaction reporting infrastructure (myDATA), which has materially increased the tax authority's visibility into business transactions.

7.2 Rulings, appeals and penalties

Advance tax rulings are available from AADE on specified matters, including transfer pricing (advance pricing agreements) and the tax treatment of proposed transactions. Disputed assessments must generally first be challenged through an administrative appeal to the Dispute Resolution Directorate before recourse to the administrative courts, with further appeal available to the Council of State on points of law. Penalties apply for late filing, late payment and understatement of tax, generally as a percentage surcharge on the tax due plus statutory interest, with more significant sanctions for cases involving fraud or systematic non-compliance; voluntary disclosure before the commencement of an audit typically attracts reduced penalties.

Because AADE's myDATA electronic invoicing framework requires near-real-time transmission of sales and expense data throughout the year, the annual return functions increasingly as a reconciliation of pre-populated data rather than a from-scratch filing, and discrepancies between reported transactions and myDATA records are a common audit trigger that taxpayers should monitor continuously rather than only at year-end.

9.1 Entity choice

The société anonyme (AE) and the private company (IKE) are the most common vehicles for inbound investment: the AE suits larger enterprises and capital-market ambitions with a minimum share capital requirement, while the IKE offers a lighter-weight, flexible structure popular with smaller and medium-sized businesses and start-ups. A branch of a foreign company is available for shorter-term or project-based engagements, taxed on attributable profits at the standard 22% rate with no branch remittance tax. Shipping-focused investors should evaluate the tonnage tax regime and Law 27/1975 ship management office status from the outset, given the materially different (and often more favourable) fiscal treatment available for qualifying maritime activity.

9.2 Structuring and incentives

Holding structures into and through Greece benefit from the EU participation exemption for qualifying EU dividends and capital gains, and from Greece's broad treaty network for third-country structuring. Investors in manufacturing, tourism, energy transition, digital transformation and R&D should evaluate development-law incentives (tax exemptions, accelerated depreciation, cash grants) and the patent box regime for qualifying IP income. Financing structures must be tested against the 30%-of-EBITDA interest limitation and the ATAD-based CFC and hybrid mismatch rules, while groups with Greek shipping operations should confirm whether the tonnage tax regime's exhaustive treatment removes the need for separate CIT and dividend withholding planning on that activity.

9.3 Worked effective-rate illustration

A Greek trading company (non-shipping, non-credit-institution) earns EBITDA of EUR 1,800,000, books depreciation of EUR 250,000, and has net interest expense of EUR 150,000, which is fully deductible as it falls within the 30%-of-EBITDA limitation and any applicable de minimis safe harbour. Taxable profit is 1,800,000 − 250,000 − 150,000 = EUR 1,400,000. CIT at the standard 22% rate is EUR 308,000, an effective rate of 308,000 / 1,400,000 = 22.0% on taxable profit, since Greece imposes no additional local income tax or minimum tax layer at the standard rate. If the after-tax profit of EUR 1,092,000 were fully distributed to a resident individual shareholder, dividend withholding of 5% would apply at shareholder level (5% × 1,092,000 = EUR 54,600), giving a combined burden on distributed profits of 22% + (78% × 5%) ≈ 25.9%.

9.4 Compliance

Expect electronic filing throughout, continuous myDATA transaction reporting, monthly or quarterly VAT compliance, transfer pricing documentation above the thresholds in section 2.9, DAC6 monitoring for cross-border arrangements, and beneficial-ownership register filings. Large groups should budget for Pillar Two registration, data collection and minimum-tax returns even where safe harbours apply, and shipping groups should maintain the specific vessel and tonnage records required to support tonnage tax filings separately from ordinary corporate tax compliance.