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We have a fully comprehensive tax practice which advises 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.

they are a top corporate full-service business law firm in Greece ... staffed with equally competent and remarkable professionals

Chambers High Net Worth Guide 2020

very strong knowledge and persistence in overcoming all sorts of problems … always there when you need them and deliver results on time

The Legal 500 EMEA 2020

excellent knowledge in the tax field … up to date with recent tax legislation developments ... efficient, value for money, responsive

The Legal 500 EMEA 2020

the team that deals with tax issues is a very strong one with excellent knowledge of the field and always updated on new regulations … available to discuss any issue and propose adequate solutions

The Legal 500 EMEA 2020

immediate advice and quality of work

Chambers Europe 2020

motivated, committed, responsive and value for money

The Legal 500 EMEA 2019

clear and analytic overview of the steps we should follow ... they updated us on new developments and legislation ... excellent service ... immediate response and availability

Chambers Europe 2019

in-depth knowledge of the issues ... agreeable, fast and always there to assist us whenever it is needed

Chambers Europe 2018

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

Chambers Europe 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 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.

€5.5m Tax Litigation

We represented before the Greek Administrative Court of Appeals the representative of an Italian legal entity in Greece in a dispute with the tax authorities regarding the assessment of additional income taxes and penalties to the legal entity of an amount of €5.5m.

Succession Tax Planning

We are advising two high net worth individuals on estates and inheritance tax issues particularly in relation to the separation of their estates in compliance with the Civil Code and Inheritance Tax Code provisions.

Liechtenstein Foundation Advice

We are advising two high net worth individuals in relation to the separation, liquidation and restructuring of a Liechtenstein foundation.

Tax Advice to PIMCO

We have been advising PIMCO on the tax aspects of the ongoing process for Project Pillar and Project Europe launched by Eurobank, involving a securitisation of residential, personal and small business loans (Project Pillar), and the tax aspects of the acquisition of a majority shareholding in FPS, a licensed servicing company that is currently fully owned and controlled by Eurobank (Project Europe).

Tax Advice on Intra – Group Merger

We advised Samsung Electronics Greece and Innoetics on the tax aspects of their merger by absorption.

Tax Structuring Advice

We are advising a software company on tax issues arising from the expansion of its activities in digital products and cross-border tax structuring issues.

Source of Funds Declaration Advice

We are advising a Greek industrial company in relation to its obligation to submit source of funds declarations on behalf of certain BOD members.

Inheritance Tax on Antiquities

We are representing a high value estate before tax authorities on inheritance tax issues relating to antiquities and have filed tax returns in relation to which the audit was successfully completed.

Tax and Customs Advice

We advised a tobacco company on the tax and customs issues arising from their purchase of shares in a Greek company and the tax structuring of their transaction and continue to advise the company on accounting, tax and customs law.

Foreign Company Establishment in Greece

We advised an international energy group on the establishment of a new company in Greece and are advising its foreign shareholder on tax issues relating to the new company.

Tax Restructuring of Acquisition

We advised Hellenic Healthcare Holding SA, a company majority controlled by funds managed or advised by CVC, on tax restructuring their acquisition of 100% of Hygeia SA, the parent company of the leading private healthcare group in Greece.

Tax Issues Arising from Transfer of Business

We advised a consumer battery company on tax implications that may arise from a potential transfer of business or sale of assets deal. We also advised on BoD members’ pension plan tax issues as well as on stock option plans for the employees.

Tax Advice Following Global Joint Venture

We advise a global leader in healthcare on the tax issues arising after their participation in a global joint venture and are advising on the development of a new distribution channel in Greece for products produced in other EU countries.

Advice on Taxation of Programming

We advise a major media company on tax issues relating to reality show contracts in Greece and Turkey, commercial agreements and special taxes applicable to TV programming.

Customs Duties Dispute

We are representing a leading distributor of luxury cars in relation to a customs duties dispute before the administrative courts and advise on stamp duties on loans within the framework of a tax audit in progress, financial leasing and profits distribution.

VAT Dispute

We successfully represented a company in litigation arising from the imposition of VAT on services provided to the Greek Navy involving a new interpretation of provisions of the tax procedure code which was accepted by the Ministry of Finance.

Tax Issues Arising from Sale of Shares

We are advising a high value estate on the tax issues arising from the sale of shares of two Cypriot companies.

Customs Advice

We are advising one of Greece’s largest automobile importers and distributors in relation to customs legislation.

Tax Implications of Sale Business

We are advising a global hygiene and personal care corporation on the Greek tax law implications of the sale of one of their businesses.

Advice on Exemptions Applicable to Real Estate Tax

We are advising a global real estate fund in relation to the documentation requirements for exemptions from special real estate taxes in the context of an investment in Greece and stamp duty applicable to cross border loans.

Transfer Pricing Dispute

We successfully represented a leading European car manufacturer in their dispute arising from wholesale prices transfer pricing between a parent entity and subsidiary.

Source of Funds Declarations

We advised an international healthcare company on issues arising from source of funds declarations.

Corporate Income Tax Dispute

We are representing a construction company in litigation arising from the imposition of corporate income tax on a special purpose tax reserve, involving an innovative method of calculation of the reserve.

Tax Issues on Conversion of Branch

We are advising a concessions company on the tax issues arising from the conversion of their Greek branch to another legal entity, the first conversion of its kind to take place in Greece.

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 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.

 

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 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.

Source of Funds Declarations

We advise Cypriot and Greek insurance companies and Greek industrial companies 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.

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.

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.

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 EIB.

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.

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.

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 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

  • 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 controversy

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