Greece: New requirements for intercompany transaction documentation

Greek businesses conducting transactions with connected entities must adhere to specific transfer pricing documentation requirements to avoid significant tax penalties. According to guidelines from NEPA Economic Consulting, companies are required to prepare a Documentation File and submit a Summary Information Table to the Independent Authority for Public Revenue (AADE).

Under Law 5104/2024, documentation is mandatory when annual transactions between connected companies exceed €100,000 for entities with a turnover up to €5 million, or €200,000 for entities with a turnover exceeding €5 million. Connected entities are defined as those with at least 33% direct or indirect ownership of capital, voting rights, or profits, as well as cases of administrative dependence.

Failure to comply can trigger audits by the Central Unit of High Net Worth Taxpayers or the Large Business Audit Center, particularly in cases of unusually low profit margins, unnatural management fees, or intercompany loans. Penalties for non-compliance can reach up to €100,000.