• NEWS
  • 21 SEPTEMBER 2020

Zepos & Yannopoulos success at Supreme Court in highly-debated foreign tax credit entitlement dispute

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Spyros Maratos

Spyros Maratos

Partner

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Daphne Cozonis

Daphne Cozonis

Partner

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Diana Tsourapa

Diana Tsourapa

Senior Associate

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Zepos & Yannopoulos won at the Supreme Administrative Court a significant tax litigation case securing a foreign tax deduction for a corporate client in the financial sector. The court decision rejected the tax authorities’ approach to prioritize the deduction of tax prepayment in Greece with lower recognition of taxes paid abroad when calculating tax liability. The court relied in its decision on the existence of a treaty for the avoidance of double taxation with the foreign tax jurisdiction thus distinguishing the case from previous case law overruling taxpayers’ foreign tax deductions, delivered in the context of domestic legislation aiming at the avoidance of double taxation. The decision could impact Greek-based profit making companies deriving revenues sourced in other countries, most notably through branches.

Our team was led by partner Spyros Maratos in cooperation with Finance & Capital Markets Tax partner Daphne Cozonis and senior associate Diana Tsourapa.