Tax

Tax

Tax & Accounting
 
The tax framework is being constantly transformed through the incorporation of international and EU rules and best practices promoting transparency and combatting tax avoidance, all amidst the ever-present effort to enhance tax collection and enforcement. Our tax & accounting practice, consisting of a team of over 40 experts with academic backgrounds in law, economics and accounting is uniquely positioned to help clients address the challenges created by the new environment. Combining the resources of a leading, internationally oriented, law firm with our thorough expertise in tax and accounting day-to-day practice, we offer our clients comprehensive assistance for creating value through managing tax impact and understanding the critical tax considerations of innovative transactions.
 
For each client, bringing together experts from our different specialized practices we work in bespoke teams that also draw from our experience on how tax matters work in specific industries with each time active partner involvement and timely delivery. A highly specialized tax team forms part of our Private clients practice.
 
Corporate tax & accounting compliance
 
Tax and accounting compliance is a value adding factor in all businesses whereas in the current increasingly complex environment poor compliance is a source of significant risk. Our corporate tax & accounting compliance team provides hands-on day-to-day advisory tax and accounting support to finance departments of corporate clients and works across the firm in a wide range of projects requiring technical tax and accounting implementation support.
  • We help clients in designing tax policies and managing compliance risk by offering tax review services on a full-scale or transaction basis
  • we undertake tax and accounting due diligence
  • we assist clients in developing, improving and monitoring tax and accounting processes 
  • we work with our M&A and corporate law teams in implementing the tax, accounting and social security aspects of setting-up, winding-up, merging, acquiring and disposing of legal entities in Greece
  • we assist clients in identifying whether accounts are reportable or not under the Common Reporting Standard (CRS) for the exchange of financial information between jurisdictions and also prepare relevant opinions
  • reporting revenues under Voluntary Disclosure programs often requires more than the standard calculations and preparation work involved in regular tax returns. We support clients in preparing and filing the relevant tax returns
  • we support clients in converting financial statements into IFRS and provide ongoing assistance for drafting
  • we provide fiscal records related advice
  • we assist clients in managing transition to new accounting systems 
  • we provide bookkeeping and tax compliance services including preparing and submitting tax return statements 
  • we provide bookkeeping and tax compliance supervision, also in the context of special operations regimes.
International tax and M&A
 
Our unique legacy of long-lasting provision of services to multinational enterprises and collaboration with global law firms combined with our country-specific and local market knowledge gives as a head start in international taxation matters and M&A work. Through our international tax and M&A team, we assist foreign and Greek clients, be it established enterprises or high-growth ventures, private equity firms and other investors, in efficiently setting up the structure of their inbound or outbound operations and investments and in managing the tax impact of complex projects and transactions, amidst the tax challenges and opportunities presented by a more and more globalized and digital economy and in the wake of OECD and EU guidance for promoting a uniform substance over form approach in the field of international taxation. 
  • We assist clients in setting up the structure of their cross-border and multi-jurisdictional operations
  • we provide to clients full support for structuring and implementing acquisitions, joint ventures, investments into Greek restructured targets, disposals and other M&A transactions, from due diligence and structuring to drafting tax related legal documentation and undertaking tax and accounting compliance and implementation
  • we review client structures, assess the impact of changes in international and domestic taxation and assist clients in the tax aspects of business reorganizations
  • we advise clients in all tax aspects of cross-border provision of services from the perspective of domestic, Tax Treaty, EU tax law and VAT
  • we advise clients on complex issues of application of Tax Treaties including in relation to permanent establishment matters
  • we advise clients on tax-related state aid matters in collaboration with our Competition law experts.
Tax controversy and Litigation
 
Recent years have seen a significant surge of challenges by the tax authorities. Our tax controversy and litigation team, with decades-long track record in representing clients in the full spectrum of tax dispute resolution processes and a deep knowledge of the workings of the tax administration system, focuses on helping clients prepare for and manage tax audits, resolve disputes at the earliest point and, if necessary, appeal before administrative authorities and courts.
  • We help clients handle tax audits and investigations, formulate strategy, conduct settlement negotiations and efficiently report on outcomes and monitor progress internally
  • we advise clients in relation to voluntary disclosure and tax penalties amnesty and relief programs
  • we act for clients in relation to tax related enforcement measures and seizures, sanctions and criminal prosecution matters
  • drawing upon our specialists in other tax practice areas, we provide combined specialized support to clients in specific highly technical tax audit challenges such as in relation to anti-avoidance rules and special industry-related tax matters
  • we act for clients in litigation for any tax related case at all levels. The cases we handle are often of high value, industry impact or complexity and we have several times obtained the issuance of ground breaking or industry-wide valuable precedent decisions. Some of the cases we have litigated involve material stamp tax assessments on debt financing and cash management schemes, transfer pricing and permanent establishment profits attribution, State aid recovery, hybrid instruments, foreign tax credits, Special Real Estate Tax
  • we work with our international taxation experts to advise clients in relation to mutual agreement procedures (MAPs) under tax treaties and the EU Arbitration Convention.
Real estate taxation
 
Our real estate taxation team acts for a multitude of clients who purchase, build, own, develop or dispose of Greek commercial, residential or industrial real estate as well as clients to whose business real estate assets are pivotal. 
 
Our clients range from individuals, including Golden Visa applicants and Greek based commercial companies to leading investment management and advisory firms, real estate funds, private equity firms, real estate developers, REITs as well as not-for-profit arts organizations. We help clients address a wide range of issues related to structuring their investments and securing compliance with property taxes.
  • Deciding what is the most appropriate structure for investing in real estate is a multilayered process which depends on a number of different parameters, such as the jurisdiction of the owner/investor, the intended use of the property, the financing scheme, the relevant commercial or personal priorities; we help clients formulate their strategy by guiding them through key tax aspects, such as the tax treatment of different available property owning vehicles, the use of input VAT deductions, the impact of property taxes, implications upon divestment
  • we compute real estate objective values with a view to ensuring compliance, and assessing the tax impact of transactions in real estate
  • Special Real Estate Tax is an annual tax introduced mostly as an anti-avoidance measure. We assist clients in assessing exemptions therefrom and –most importantly- collect the documentation required to secure such exemptions
  • we provide specialized advice, together with our banking & finance taxation team on real estate acquisition financing structures
  • we work on NPL restructuring projects and NPL related business set-ups by providing specialized real estate related advice.
Transfer Pricing
 
Amidst a more and more globalized economy and within the context of the Base Erosion and Profit Shifting (BEPS) project of the OECD, which, along with European Union and local developments, has transformed the way enterprises develop, document and advocate their transfer pricing policies, our transfer pricing team, comprising professionals with academic backgrounds in law and economics with significant experience in international tax, helps clients proactively address the transfer pricing challenges and opportunities.
  • We help clients design their transfer pricing strategy and assist in the economic analysis of transactions
  • we advise on cross-border supply chain structuring and deployment of intangible assets, in the light of OECD guidelines and revised domestic legislation on business restructurings
  • we provide assistance in negotiating and putting into place Advanced Pricing Arrangements with tax authorities including rulings for local service centers (formerly known as Law 89 entities)
  • we support clients in transfer pricing audits
  • we handle transfer pricing litigation at a domestic and cross-jurisdictional level
  • we assist clients in complying with annual transfer pricing documentation and benchmarking requirements.

VAT, Indirect tax and Customs

VAT forms an indispensable aspect of the business most of our clients are engaged in. Our VAT, Indirect tax and Customs team experts, often working in collaboration with colleagues across the firm in a variety of projects and industries, combine the pragmatic, each time industry-specific approach with the in-depth legal and accounting expertise required to assist clients in managing their indirect tax position.

  • VAT is key in sectors such as the digital economy and real estate: our experts help clients to factor-in and optimize the impact when structuring the set-up of their operations
  • irrecoverable VAT, arising in situations such as bad-debt cancellation, may significantly impact cash flow and the business: we handle the entire process of VAT refunds, from feasibility assessment to book-keeping support and litigation
  • we advise on special VAT regimes and exemptions such as the tour operators margin scheme (TOMS) and shipping exemptions
  • we work with our banking & finance team to assess the VAT aspects of finance sector related transactions, including NPL and debt portfolio restructurings
  • our book-keeping and tax compliance activities are enhanced with VAT-specific expertise
  • we advise on insurance premium tax, tonnage tax, municipal duties.
Banking & finance
 
Our dedicated banking & finance taxation team has developed a unique experience in dealing with innovative transactions in the finance industry sector. We provide tax services to banks, insurance companies, investment funds, investment banks and other financial institutions and assisting our clients in structuring, assessing and managing the tax impact of any financing related transaction
We assist clients in the tax matters surrounding the tax structuring and implementation of transactions ranging from traditional corporate finance to structured finance, asset finance, securitizations, project finance
  • we advise global financial services firms and other clients on the taxation of trading Greek listed securities and relevant securities financing transactions
  • we advise on the taxation of NPL portfolio acquisition and servicing transactions and NPL restructuring
  • we provide specialized tax advice on corporate taxation matters for banks, insurance and other finance industry sector companies
  • we provide tax opinions, draft tax clauses and tax sections of legal documentation related to debt and equity issuance
  • we provide tax advice in relation to funds and collective investment schemes, investment products and innovative debt, equity and hybrid instruments.
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