Transfer Pricing in Greece represents a fundamental element of contemporary tax policy. This matter regulates transactions between related parties to ensure fair taxation and prevent artificial profit shifting.

The Greek legal framework is mainly governed by Law 4172/2013 and Law 5104/2024, which align national rules with international standards and best practices.

Principles and aspects of Transfer Pricing in Greece

At the core of the transfer pricing regime in Greece lies the arm’s length principle, as defined by the OECD Guidelines. According to this principle, transactions between related entities must be conducted under comparable conditions to those that would apply between independent parties in similar circumstances. This ensures that taxable profits are allocated fairly and reflect economic reality.

A crucial condition for the application of transfer pricing rules is the identification of related parties. Based on Greek legislation, entities are considered related when one participates directly or indirectly in the management, control, or capital of another. The established threshold is a minimum participation of 33%. This definition also encompasses entities under common control.

Documentation requirements depend on materiality thresholds. Transfer pricing documentation is mandatory when annual transactions with related parties exceed:

• EUR 100,000 for companies with a turnover of up to EUR 5 million.
• EUR 200,000 for companies with a turnover exceeding EUR 5 million.

Transfer Pricing and its obligations

Taxpayers exceeding these limits must prepare a ‘Master File’ and a ‘Local File’. The first document describes the structure and activities of the multinational group, while the Local File focuses on the transactions and pricing policies of the Greek entity.

Additionally, companies must electronically submit a “Summary Information Table” along with their annual tax return. Multinational groups with consolidated revenues exceeding EUR 750 million are also required to file a Country-by-Country Report (CbCR) within twelve months following the close of the fiscal year.

Fines and penalties in Greece

Non-compliance with transfer pricing obligations can lead to substantial sanctions. This would result in fines linked to the value of the transactions and stricter penalties for failure to file.

Consequently, transfer pricing in Greece should be considered not only as a formal requirement but as a strategic tax and governance matter. This process requires continuous monitoring, robust internal controls, and specialized professional expertise.

The Greek economy is growing following the successive global recessions of recent decades. The country offers various investment opportunities to multinationals. If you are interested in our transfer pricing management, you can consult our experts.

At Auxadi, we offer comprehensive services in accounting, tax, payroll, transfer pricing and corporate legal services to multinationals and funds. With experience since 1979 and a presence in over 50 countries, including 26 proprietary subsidiaries, our advanced technological platform, MySPV, and proven methodology enable us to guarantee efficient management in compliance with local regulations.