Successful resolution of cash pooling stamp tax dispute

Our tax litigation team has successfully challenged before the Court of Appeals a stamp tax assessment of EUR 633k concerning deposits made by a Greek subsidiary of a multinational group in the context of cash pooling arrangements. Despite the consistently negative case law concerning stamp tax assessments, our team achieved the annulment of the assessment, legally establishing that the obligations from cash pooling schemes are not executed in Greece, as per the territoriality rule of the stamp tax legislation. Taking into account that cash pooling arrangements among multinational groups are quite common, the decision in question is important, since in the last years cash pooling arrangements are targeted by tax authorities, who proceed with heavy assessments thereon.

Leading lawyers: Alex Karopoulos and Evangelia Yotakou