Tax

Tax

Our tax practice, acknowledged as the largest and most specialized in any law firm in Greece, offers the full range of tax services on both a transactional and ongoing basis to clients doing business in Greece. Our tax consultants provide top quality, business oriented and proactive tax support, often working together with our legal experts and consultants in our affiliated company Zeya Accounting for the provision of comprehensive legal and tax services. 

Zepos & Yannopoulos is consistently – over at least 10 years- ranked the No. 1 tax practice in Greece, by all major international legal directories and our firm was voted in 2008, 2009 and 2010 as Tax Firm of the Year for Greece by the International Tax Review.

Our tax practice members participate in several professional informal clubs and networks of international tax experts and we often provide joint assistance to multinational clients working together with major international law firms.

Our tax expertise spans the following areas:

Corporate and M&A Taxation

One of the pillars of our firm’s taxation practice is the provision of tax consultancy services to our corporate clients in relation to the conduct of their business in Greece. With a team of highly specialized professionals, we offer sophisticated and proactive advice and help our multinational clients in maximizing tax efficiency while at the same time understanding the intricacies of the Greek tax system and complying with local regulations. Our experts within our corporate taxation practice specialize in different areas and sectors such as mergers and acquisitions, banking and finance, transfer pricing, tax due diligence, corporate and project finance, double tax treaties. We offer our clients tax advice on establishment, operation and financing of their businesses in Greece, on divestment strategies, on permanent establishment issues, on corporate taxation aspects of complex commercial arrangements, on tax structuring for mergers, share and asset deals, joint ventures, leveraged buy-outs and internal restructurings. Our experts often work with international law firms to deliver seamless advice for the domestic aspects of international transactions. Moreover, we offer corporate taxation and tax compliance day-to-day support to several clients and we are often called to assist our clients in the handling of tax audit procedures. 

Clients regularly advised by our firm’s tax practice include Chevron, Cadbury, ExxonMobil, Hewlett Packard, Iberdrola, Intesa Sanpaolo, Nokia, Nike, Tupperware. 

Transfer Pricing

Transfer pricing is of growing concern for our multinational clients and an issue which is becoming more complex locally, in the wake of newly introduced legislation and the increasing awareness and sophistication of the local tax authorities. Our transfer pricing team offers clear and careful advice on the implementation of global transfer pricing policies in compliance with local rules, including local documentation and reporting requirements, and assists clients in assessing, managing and planning related transfer pricing issues. The team’s members often provide their expert advice on the tax issues surrounding a variety of intra-group transactions handled by other groups of our firm. Transfer pricing related dispute resolution on the basis of both domestic and EU legislation is an area in which our team regularly engages for our clients.

An indicative list of multinational clients that we have been assisting on transfer pricing includes AkzoNobel, Amadeus, Chevron, CombiTrans, ExxonMobil, Leaseplan, Media Saturn, Oriflame, Pierre Fabre, Remy Cointreau, Tupperware and Universal Music. 

VAT and Indirect Tax

Our firm includes an expert team of lawyers who are specialized in providing advice on indirect tax with particular emphasis on VAT, stamp tax, customs duties and insurance premium tax. Our indirect tax team advises clients as well as other tax and legal experts within our firm in understanding the complexities of VAT and other indirect tax issues and enhancing the indirect tax position for both cross-border and local transactions ranging from plain commercial agreements and activities in Greece to public procurement, banking and real estate transactions as well as corporate reorganizations, mergers and acquisitions. The team also assists clients or collaborates with other experts within the firm in relation to indirect tax audits, VAT refund claims and related litigation. In this context, our indirect tax experts have more than once initiated before the European Commission proceedings for resolving incompatibilities between Greek VAT law and European VAT law. 

Taxation of Real Estate Property Investments

Our team of real estate tax and legal experts has dealt with many of the largest and most complex real estate transactions to have taken place in Greece. We are thus specialized in offering tax effective and flexible solutions for structuring the acquisition, holding, development and commercial exploitation or other use of real estate property for a great variety of purposes (office buildings, residential property, commercial centers, cinemas, hotel buildings & leisure sites, industrial sites, warehousing & logistics facilities, fuel terminals, blending plants, mines & quarries, etc). We also advise on divestments from real estate property such as exit strategies, repatriation of profits, international tax implications etc. Our clients include major international firms, developers, development consultants, financial institutions and investors (both resident and non-resident) who seek to assess and administer all tax liabilities arising in Greece (such as corporate income tax, stamp tax, property tax, municipal tax and VAT).

Tax Litigation

Our tax practice comprises the largest fully dedicated tax litigation practice in the country. Important referrals from both clients and other consulting firms evidence our prominent position in this area for over 50 years. Our tax litigation team has developed unrivalled experience and knowhow by handling numerous and varied tax and customs disputes, ranging from the preparation and filing of a tax refund claim to the defense of our clients before any court, including the European Court of Justice, in complex tax or customs controversies. We handle tax collection disputes in relation to all types of taxation and have successfully litigated, often through multi-disciplinary teams of tax experts, cases involving major corporate taxation, fiscal documentation, VAT and excise and import duties. Our tax litigation practice is also actively engaged in providing advice, on a proactive or upon-request basis, on a variety of procedural aspects of tax and customs legislation such as tax reporting and compliance, corrective actions, limitation periods, tax amnesty and debt settlements, as well as mutual administrative assistance and related procedures. Moreover, in leading our domestic and international clientele through the procedural intricacies involved in all stages of tax and customs controversy, we often assist them in understanding the auditing practice of the Greek tax and customs authorities and evaluating the potential success of possible litigation.

Private Clients and Employment Taxation 

Our individual tax practice specializes in tax and estate planning as well as tax compliance for high-net-worth individuals, multinational families, senior executives and charitable organizations. We offer advice on planning and implementing efficient tax structures in areas such as funds, the acquisition, holding and disposal of real estate as well as family businesses. In this context, apart from directly advising individuals, we also assist corporate clients involved in relevant sectors -such as private banking- in assessing tax implications for their own private clients. Foundations and non-profit organizations as well as foreign trust structures are often put into the ambit of our specialized tax advice. In understanding the needs of our clients and offering proactive support, we often perform tax reviews for evaluating their tax compliance level, be it in the field of real estate, inheritance, donation or income taxation. We also prepare and file all types of tax returns for many of our individual clients, assist them in tax dispute resolutions and litigation on any type of taxation and offer advice to senior executives of our corporate clients on various issues such as taxation of multinational employment, stock compensation or insurance plans and administrative or criminal liability for corporate tax offences.

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