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Our team have a comprehensive tax practice, advising private and public companies, partnerships and individuals, both on a standalone basis and as part of an integrated service across our transactional and disputes teams.

very prompt and thorough advice on a very complicated issue for which there was no previous jurisprudence to provide guidance

Chambers Europe Guide to Europe's Leading Lawyers for Business 2017

prompt response times

The Legal 500 EMEA 2017

what is positive, in particular, is the fast reaction to our requests and the fact that there is always one specialised lawyer for the issue requested to help you out

Chambers Europe Guide to Europe's Leading Lawyers for Business 2016

We identify, anticipate and deal with tax issues, risks and compliance arising in a business or private context. We have represented clients in relation to the amendment of adverse legislative provisions and submitted reports to the Ministry of Finance proposing legislative changes, with a focus on tax incentives for attracting foreign investors.

Corporate Advisory

We have extensive experience in advising on company structuring, operation, planning and policy, asset ownership, executive and employee remuneration and benefits from a tax perspective. Our aim is to provide innovative solutions to complex issues, such as mitigating regulatory risk and meeting challenges and to prepare our clients for legislative changes. Our practice works closely with correspondent law firms and advisors on cross-border structuring and liability, the effect of double taxation treaties and transfer pricing. We also advise on VAT and all other types of indirect taxes and the tax treatment of the provision of services and supply of goods.

Corporate Transactional

Our team provides highly technical advice on the tax structuring, planning and implementation of a wide variety of corporate transactions, including securities offerings, financings, cross border and local mergers and acquisitions, reorganisations, restructurings and insolvencies, as well as inward and outward investments. We place emphasis on factoring in the risks of prospective or retrospective changes to legislation which will affect the life of a transaction or investment. Many of the deals we advise on have a cross-border aspect or involve companies which are active globally, and we work with international advisors and law firms to meet the challenges such transactions present and assimilate the obligations of the countries involved. We also advise extensively on the direct and indirect tax aspects of the sale and purchase of real estate and other assets.

Investigations & Disputes

Our team has extensive experience in acting in tax controversy matters arising from liability to a wide variety of issues, including corporate and personal tax, indirect taxes, regulatory and legislative compliance, transfer pricing, tax adjustments and accounting, bad debt provisions, fund transfers abroad and debt to equity issues. We represent individuals, partnerships and corporations in investigations, audits and dawn raids, and before the Tax Authorities and Administrative Courts and in challenges to Tax Authority decisions, technical enquiries, applications for rebates and settlements of fines and tax bills.

Wealth & Estate Planning

Our team is highly experienced in advising individuals and families on wealth and estate planning, the protection of assets, cross-border and domestic estate administration, the implications of the implementation of the OECD Guidelines and EU Directives on exchange of information. We offer advice on personal tax liabilities, post-death planning, co-ownership of assets and establishing family offices. We have an expertise in wealth and succession planning, often developing innovative structures to enable our clients to make use of, transfer and eventually devolve their wealth. We also represent clients in high value tax and estate disputes.

Who to contact

Contact Panayotis
Contact Fotodotis

Recognitions

 

Due to the highly sensitive and confidential nature of the work we do in this area, we are able to disclose only a fraction of the matters we have advised on.

Tax Treatment of Employment and Benefits

We advised a global packaging company on the employment tax treatment and corporate tax deductibility of benefits granted to its officers and factory employees to support the operational needs of the business in the context of the implementation of the new income tax law and the interpretative issues surrounding the impact of the new provisions on company practices and following which interpretative guidelines were introduced.

Taxing of Banking Services in Context of Wealth and Estate Planning

We are advising a leading international banking institution in relation to the taxation of banking services and products in Greece, the tax implications for Greek and non-Greek tax residents and the tax structuring of the entity through which the services and products will be offered. The client is planning to offer a combination of financial advisory and banking services, together with various financial products, under a format and structure not previously used in Greece. Following implementation of the new income tax code as of 1 January 2014, and the changes effected to the basic rules of taxation, all banking services and products are being reconsidered to safeguard compliance with the tax laws.

Tax Implications of Restructuring in Energy Sector

We advised an energy company on the tax implications of its restructuring following the disinvestment by its joint venture partner in Greece and resulting issues arising, including on outstanding loans to the joint venture entity which needed to be restructured and on the complex tax issues arising and the structuring of the new entity.

Tax and Social Security Liability Advice

We advised a natural cosmetics company on the tax and social security insurance liability of board members and shareholders, involving the implementation of new legislation which has not yet been tested.

Advice on Interpretation of Tax Provisions on Law Regulating Online Betting

We are advising a world leader in online betting systems on its consultation with the Ministry of Finance and the Gaming Committee regarding the interpretation of the tax provisions of the law regulating online betting, the direct and capital tax obligations arising, and the potential restructuring of the group’s operations to satisfy tax requirements and the regulatory framework for investing in the Greek market. Online betting is not yet a fully regulated market in Greece. EU operators were granted the right to lawfully operate in Greece under a transitional regime, provided they paid Greek taxes retrospectively.

Council of State Petition of Ministry of Culture Decision and Advice on Retrospective Application of Income Taxes

We are representing a high value estate in relation to their petition lodged with the Council of State for annulment of the Ministry of Culture’s decision on the inheritance of antiquities pursuant to the legislation governing the protection of antiquities and in relation to a tax investigation regarding cash transfers outside Greece following sale of Greek real estate.

Tax Advice in Insurance Sector

We advised a leading French multinational insurance group on the direct and indirect tax implications of restructuring its European activities, involving the registration of a branch in Greece and contributions to some local operations in accordance with EU tax incentive legislation on cross – border restructurings.

Tax Implications of GSK – Novartis Merger

We acted with the UK legal advisors of Glaxo SmithKline, advising on the direct and indirect tax implications and implementation of their acquisition of Novartis’ vaccines business in Greece and the local consumer healthcare joint venture between the two companies.

Tax Compliance and Reporting

We advised a physician and professor at a Greek University on his tax compliance and reporting obligations from pursuing activities outside the scope of his academic duties.

Tax Law Issues Affecting HNWIs

We are advising a Swiss law firm on the Greek tax law issues affecting Greek HNWIs, specifically on income tax law obligations, statute of limitations and voluntary disclosure requirements, as well as on gift and inheritance tax issues in the case of domiciled and non-domiciled tax status and Greek and non-Greek assets.

Tax Implications of Bad Debt Write Off Procedure

We advised a car distributor on the bad-debts write-off procedure and possible tax and accounting implications and VAT issues related to credit facilities and potential tax implications and drafted sample notifications for distribution to clients.

Source of Funds Declaration

We advised a credit company on the recent developments regarding the source of funds declaration that must be submitted by board member to the Greek State.

Tax Treatment of Life Insurance Products

We are advising a multinational insurance company on the corporate tax implications and Greek tax treatment of life insurance contracts offered under the freedom to provide services rules and applied for by Greek tax residents.

Hewlett Packard Tax Advice on Reorganisation

We advised Hewlett Packard on the direct and indirect tax implications and implementation of the separation in Greece of the Hewlett Packard infrastructure, software and services businesses from the printing and personal systems businesses.

Clothing Manufacturer Tax Assessment Dispute

We successfully represented the subsidiary of a global leader in retail before the Administrative Resolution Committee and the Administrative Courts in its dispute with the tax authorities regarding the assessment of additional income taxes, stamp duty and penalties, following the issuance of a tax audit report on accounting differences and stamp duty liabilities of €1.5m. The Greek tax authorities treated the amounts recorded in the customers’ balances account as company loans to customers and imposed deemed interest income and stamp duty on the relative amounts. The recourse was accepted and a decision issued in favour of our clients.

Real Estate Group Tax Assessment Dispute

We represented the subsidiary of a real estate investment fund before the Administrative Courts in its dispute with the tax authorities regarding the assessment of additional income taxes and penalties, following the tax audit reports on the classification of lease payments equal to €4m. The tax authorities treated part of the lease payments paid by the company to the financial lessor as a non-tax deductible expense. The recourse was re-submitted to the Courts following an amnesty provision introduced recently and a decision in favour of our client was issued.

Marks & Spencer Group Tax Assessment Dispute

We successfully represented the subsidiary of Marks & Spencer Group before the Administrative Courts in its dispute with the tax authorities regarding the assessment of additional income taxes and penalties following an audit calculating income tax on the amount of €1m corresponding to the value of obsolete merchandise destroyed.

Tax Assessment Dispute

We represented the subsidiary of a global leader in hygiene products in its dispute with the tax authorities regarding the assessment of additional income taxes and penalties, following an audit on accounting differences of €5.5m, which resulted in an out-of-court settlement.

Re-domiciliation Implications

We advised a high net worth individual with dual citizenship on the tax implications arising from re-domiciliation to Greece and the conduct of worldwide business activities from Greece.

Tax Implications of Real Estate Ownership

We advised a high net worth family with Ukrainian and Greek dual nationality on the tax law aspects, tax residency status, citizenship rules and potential tax obligations arising from the ownership of rights to real estate situated in Greece.

Eurobank Ergasias Share Capital Increase

We advised Eurobank Ergasias on the tax implications of their share capital increase scheme, following the implementation of the new income tax law, which resulted in interpretative issues arising regarding the taxation of the share capital increase schemes and the basis of calculation for the taxes due, which led to the amendment of the law.

Eurobank Ergasias Share Capital Increase

We advised Eurobank Ergasias on the tax implications of its share capital increase scheme, in the context of the recapitalization provisions, included in the 2015 Austerity Measures for Greek financial institutions and the potential tax risks arising from changes in the practice followed by the tax authorities.

Hellenic Telecommunications Organisation (OTE) Bonds Issue Update

We advised OTE on the tax implications of its bonds issue update scheme, following the implementation of the new income tax law which resulted in many interpretative matters regarding the taxation of the bond issue and treatment of the income arising from the holding and sale of the bonds.

Tax Implications of Liquidation of Airline Branch

We are advising an airline on tax compliance and reporting obligations arising from the liquidation of its Greek branch.

VAT Treatment of Promotional Activities

We advised a leading automobile manufacturer on the VAT implications arising from promotional activities relating to an energy company.

EIB Financing of Energy Power Provider

We advised the subsidiary of a global leader in energy power on the direct and indirect tax implications arising from its financing by the European Investment Bank.

Tax Implications of Corporate Structure for Technical Works Project

We are advising an overseas investor in the context of an international technical project on the tax structure options available for the execution of the local leg of the transaction and the interpretation issues arising from the implementation of IFRS to the accounting treatment of the project.

Asset Restructuring and Distribution

We advised a high net worth individual on the tax implications arising from asset restructuring and distribution of estate assets to family members.

Tax Investigation

We represented a high net worth individual with dual citizenship in an investigation by the tax authorities regarding the transfer of €10m out of Greece following the sale of Greek real estate assets and taxation of the sale proceeds.

Tax Audit of Transferred Funds

We represented a high net worth individual in the tax audit of €3m transferred out of Greece.

Tax Assessment Dispute

We represented a high net worth individual in his dispute with the tax authorities regarding the assessment of additional income taxes and penalties of an amount equal to €1.3m, following an audit on funds transferred out of Greece. The out of court settlement petition was accepted and a decision issued in favour of our client.

Retrospective Application of Special Real Estate Taxes

We advised an overseas foundation in relation to its case before the tax authorities with respect to the retrospective application of special real estate taxes.

Common Custom Tariff and VAT Advice

We advised the local distributor of a market leader in the global clinical nutrition industry on the Common Custom Tariff classification and VAT treatment of various imported and marketed products following the amendment of the law governing the application of reduced VAT rates.

Retail Group Change in Transfer Pricing Policy

We advised the subsidiary of a global leader in retail on the change of its transfer pricing policy, related tax considerations and redrafting of agreements.

Tax Compliance Audit

We advised a global ICT solutions provider on the tax and customs laws and regulations applicable to the operations of its Greek subsidiary and the penalties imposed for non-compliance.

Tax Implications of Corporate Structure for Inward Investment

We advised an Arab investment fund on the tax implications and implementation of a corporate structure for inward investment and the acquisition, holding, development and potential sale of real estate with a value of €110m.

Tax Aspects of Expansion of Lending Activities

We advised a global banking and finance group on the tax implications arising from the expansion of its lending activities in Greece, specifically on the conduct of lending activities via its US or EU based subsidiaries, guarantees on Greek assets and their forfeiture.

Piraeus Bank Bonds Issue Update

We advised Piraeus Bank Group on the tax implications of its bonds issue update scheme, following the implementation of the new income tax law which resulted in interpretative issues regarding the taxation of the bond issue and treatment of the income arising from the holding and sale of the bonds.

  • corporate and individual income tax
  • indirect tax, VAT and stamp duty
  • transfer pricing
  • tax aspects of transactions, investments, financing techniques, asset acquisition and disposal
  • tax incentives
  • double taxation treaties, foreign tax credits and thin capitalisation rules
  • tax aspects of cross border personnel structures
  • taxation of employee benefit schemes
  • customs, tariffs and duties
  • estate planning
  • wealth planning
  • asset protection
  • continuity of estates and businesses
  • trusts and foundations
  • tax controversycorporate and individual income tax
  • indirect tax, VAT and stamp duty
  • transfer pricing
  • tax aspects of transactions, investments, financing techniques, asset acquisition and disposal
  • tax incentives
  • double taxation treaties, foreign tax credits and thin capitalisation rules
  • tax aspects of cross border personnel structures
  • taxation of employee benefit schemes
  • customs, tariffs and duties
  • estate planning
  • wealth planning
  • asset protection
  • continuity of estates and businesses
  • trusts and foundations
  • tax controversy