Transfer Pricing ' Reverse Tax Reform

• Published date: 10 November 2022
• Subject Matter: Accounting and Audit, Tax, Audit, Income Tax, Transfer Pricing
• Law Firm: Eurofast
• Author: Mr Maria Anastasiou

A radical decision was taken by the Greek Parliament with the adoption of Article 171 of Law 4972/2022.

The Official Gazette dated September 23 paves the way for reverse reforms that reduce the tax results of affiliated Greek entities.

A prerequisite for the application of the above is a finalized tax audit in the part where an equal taxable results increase has been performed and additional tax has been discharged.

The other party to the transaction can then file an amended income tax return, including a reverse tax adjustment, but the audit report of the first taxable person must be filed together.

More specifically it states: "Exceptionally, if according to par. 1, the profits of a legal person or legal entity, which are subject to tax in Greece, include profits which are subject to...