Greece transfer pricing (tax year 2026)

Source-cited draft: not reviewed by an accountant, not for filing.

Greek transfer pricing rules sit in two codes. The Income Tax Code (Κώδικας Φορολογίας Εισοδήματος, ΚΦΕ, ν. 4172/2013) defines connected persons (art. 2(ζ)) and sets the arm's length rule (art. 50) and the rule for business restructurings (art. 51). The Tax Procedure Code (Κώδικας Φορολογικής Διαδικασίας, ΚΦΔ) sets the documentation file and Summary Information Table (art. 25), advance pricing agreements (art. 26) and the fines (arts. 55 and 56).

Renumbering. The Tax Procedure Code was re-enacted as ν. 5104/2024 (Α' 58). The old numbers in ν. 4174/2013 still appear in older guidance and in many firms' templates. AADE's correspondence table maps them: old art. 21 is now art. 25 (documentation file), old art. 22 is now art. 26 (APA), old art. 56 is now art. 55 (documentation fines) and old art. 56A is now art. 56 (country-by-country and DAC6 fines). The AADE codification read for this skill (circular Ε.2109/2025) is updated to ν. 5259/2025 (Α' 228/12.12.2025). It shows no amendment by a 2025 law to arts. 25, 26, 54, 55 or 56.

Related skills: gr-corporate-income-tax (the 22% rate, the taxable base, the return), gr-cross-border (residence, withholding, the company exit tax of art. 66A), gr-income-tax (individuals). This skill does not repeat them.

Who this applies to

Connected persons (ΚΦΕ art. 2(ζ)). A connected person is anyone who takes part, directly or indirectly, in the management, control or capital of another person, who is a relative of that person, or who is linked to that person. In particular:

• a person who holds, directly or indirectly, shares, units or capital of at least 33%, by value or number, or rights to profits or voting rights (art. 2(ζ)(αα));
• two or more persons, if one person holds, directly or indirectly, at least 33% of shares, units, voting rights, capital or profit rights in each (art. 2(ζ)(ββ));
• any person with a direct or indirect relationship of substantial management dependence or control over another, or who exercises or can exercise decisive influence over another, or two persons both under such dependence, control or influence of a third person (art. 2(ζ)(γγ)).

A "relative" (συγγενικό πρόσωπο) is a spouse and ascendants or descendants in a direct line (art. 2(στ)).

The arm's length rule (ΚΦΕ art. 50). It applies to legal persons and legal entities that carry out one or more transactions, domestic or cross-border, with connected persons on terms that differ from those between independent businesses. The profit they would have made on arm's length terms is added to their profits, but only to the extent this does not reduce the tax payable (art. 50(1)). The rule is applied and read under the OECD transfer pricing guidelines (art. 50(2)). Art. 50 is written for legal persons and entities; it does not name individuals carrying on a business.

Business restructurings (ΚΦΕ art. 51). A transfer of functions, assets, risks or business opportunities between connected persons is valued as a "transfer package" at arm's length, taking account of the whole value of the assets, functions and risks moved.

Documentation duty (ΚΦΔ art. 25(1)). Connected persons within ΚΦΕ art. 2(ζ) keep a documentation file (Φάκελος Τεκμηρίωσης) for their transactions under ΚΦΕ art. 50 and their transfers of functions under art. 51. So do Greek permanent establishments of foreign businesses, for dealings with their head office or with persons connected to it, and Greek legal persons and entities for dealings with their own permanent establishments abroad.

Who is exempt (ΚΦΔ art. 25(2) and (6)).

• Transactions and transfers of functions together up to EUR 100,000 in the tax year, where the taxpayer's turnover does not exceed EUR 5,000,000; or
• transactions and transfers of functions together up to EUR 200,000 in the tax year, where turnover exceeds EUR 5,000,000.
• Companies and branches set up under α.ν. 89/1967 are exempt from documenting their intra-group transactions.

A taxpayer under these limits keeps no file and files no Summary Information Table (art. 25(3)). It is still bound by the arm's length rule of ΚΦΕ art. 50.

Rates, bands and thresholds

Item	Rate or amount	Year	Source
Ownership test for connected persons	At least 33% of shares, units or capital (by value or number), or of profit rights or voting rights, direct or indirect	2026	ΚΦΕ art. 2(ζ): https://minfin.gov.gr/wp-content/uploads/2026/04/ΚΩΔΙΚΟΠΟΙΗΣΗ-ΤΟΥ-ΚΩΔΙΚΑ-ΦΟΡΟΛΟΓΙΑΣ-ΕΙΣΟΔΗΜΑΤΟΣ-ΜΕΧΡΙ-ΤΟ-Ν-5264-2025.pdf
Exemption from the file and ΣΠΠ, turnover up to EUR 5,000,000	Connected transactions up to EUR 100,000 in the tax year, in total	2026	ΚΦΔ art. 25(2)(α): https://www.aade.gr/sites/default/files/2025-12/e2109_2025.pdf
Exemption from the file and ΣΠΠ, turnover over EUR 5,000,000	Connected transactions up to EUR 200,000 in the tax year, in total	2026	ΚΦΔ art. 25(2)(β)
Production of the file on request	Within 30 days of receiving AADE's request	2026	ΚΦΔ art. 25(4)
Updating a file used again for the next year	Within 4 months of the end of the tax year in which the update became necessary	2026	ΚΦΔ art. 25(5)
ΣΠΠ filed late, or inaccurate or incomplete	1/1000 of the transactions that had to be documented, at least EUR 500 and at most EUR 2,000	2026	ΚΦΔ art. 55(1)(α)
ΣΠΠ not filed	1/1000 of the transactions that had to be documented, at least EUR 2,500 and at most EUR 10,000	2026	ΚΦΔ art. 55(1)(β)
File produced on day 31 to 60 after the request	EUR 5,000	2026	ΚΦΔ art. 55(1)(γ)
File produced on day 61 to 90	EUR 10,000	2026	ΚΦΔ art. 55(1)(γ)
File produced after day 90, or never	EUR 20,000	2026	ΚΦΔ art. 55(1)(γ)
Inaccurate return fine on the tax difference after an adjustment	10% if the difference is 5% to 20% of the declared tax; 25% if over 20% and up to 50%; 50% if over 50%	2026	ΚΦΔ art. 54(1)
Unilateral APA decision period	18 months from the application (AADE Governor may set a longer period, at most 36 months)	2026	ΚΦΔ art. 26(3)(α); art. 83(30)
APA maximum term	4 years	2026	ΚΦΔ art. 26(3)(α)
Country-by-country report: group size	Consolidated group revenue of EUR 750,000,000 or more (pro rata for a fiscal year shorter than 12 months)	2026	AADE decision Α.1341/2019 amending ΠΟΛ 1184/2017: https://aade.gr/sites/default/files/2019-09/a1341_2019fek.pdf
Country-by-country report deadline	12 months after the last day of the group's reporting fiscal year	2026	Α.1341/2019
Country-by-country report not filed	EUR 20,000	2026	ΚΦΔ art. 56(α)
Country-by-country report late or inaccurate	EUR 10,000	2026	ΚΦΔ art. 56(α)
Corporate tax rate on an adjustment	22%	2021 onwards	ΚΦΕ art. 58(1)(α)

The taxable base

The adjustment. Where a Greek company's terms with a connected person differ from arm's length terms, the profit it would have made is added to its taxable profit (ΚΦΕ art. 50(1)). The rule only works one way: it can increase the tax payable, never reduce it. A company cannot use art. 50 to lower its own profit because it overpaid a connected supplier.

Corresponding adjustment inside Greece (ΚΦΕ art. 50(1A)). If an audit adds profit to one Greek-taxed company, and the same profit is taxed in Greece in the name of a connected legal person or entity, that second company may ask for a matching adjustment to its own taxable profit. It does this by filing an amended return, with notice of the audit report on the first company. Transitional rules for older cases are in ΚΦΕ art. 72(84).

Restructurings (ΚΦΕ art. 51). A transfer or licence of goodwill or intangibles in a restructuring is paid for at arm's length, valuing the whole transfer package. No adjustment follows if the taxpayer shows that no significant intangibles or assets were transferred or licensed and that arm's length payment was made. If it cannot show this and no comparable exists, the price is set on the whole package, taking account of the present value of expected future profits. The taxpayer may use another method if it shows the result is at arm's length. The adjustment is made for the year of the restructuring.

The file (ΚΦΔ art. 25(3) to (5)). The file consists, as the case requires, of a Master File (Βασικός Φάκελος Τεκμηρίωσης) and a Greek Local File (Ελληνικός Φάκελος Τεκμηρίωσης). It must include a chapter on events that affect its information because of a change in market conditions; the taxpayer updates it by the end of the tax year in which the change happens. A file can be reused for the next year if it is updated with all needed changes. The exact content of the file, the Master File, the Local File and the ΣΠΠ, when a file counts as incomplete, and the accepted methods are set by decision of the AADE Governor (ΚΦΔ art. 83(29)). AADE's transfer pricing page lists ΠΟΛ 1097/2014 (Β' 883/9.4.2014), issued under old art. 21, and its amendment ΠΟΛ 1144/2014 as the decisions on the file's content. This skill does not set out their content. The same power lets the Governor set a simplified procedure for micro and small entities and exemptions for micro entities (art. 83(29)).

Interest, guarantees and other financial transactions. Greece applies the OECD guidelines (ΚΦΕ art. 50(2)), so intra-group loans, guarantees and cash pools are priced under the OECD method. The interest limitation rule (ΚΦΕ art. 49) is separate and is not covered in this pack yet.

Deadlines and filing

What	When	Source
Prepare the documentation file	By the deadline for the annual income tax return	ΚΦΔ art. 25(3)
Summary Information Table (ΣΠΠ)	Filed electronically with AADE within the same deadline, for every tax year in which the taxpayer is not exempt under art. 25(2)	ΚΦΔ art. 25(3)
Income tax return of a legal person or entity, calendar tax year 2026	15 March to 15 July 2027. A company whose year ends on another date files by the last working day of the sixth month after its year end	ΚΦΕ art. 68(2)
Keep the file	At the taxpayer's seat, for as long as the books and records of that year must be kept	ΚΦΔ art. 25(4)
Produce the file to AADE	Whenever asked, within 30 days of receiving the request	ΚΦΔ art. 25(4)
Update a reused file	Within 4 months of the end of the year in which the need to update arose	ΚΦΔ art. 25(5)
Country-by-country report	12 months after the end of the group's reporting fiscal year	Α.1341/2019
Country-by-country notification by a Greek group member	By the last day of the group's reporting fiscal year	Α.1341/2019

So for a company with a calendar 2026 year, the file must be ready and the ΣΠΠ filed by 15 July 2027.

The documentation file is not filed. It is kept and handed over within 30 days if AADE asks for it. Only the ΣΠΠ is filed each year.

Penalties and interest

All from the Tax Procedure Code (ν. 5104/2024). The fines in art. 55 replace the general late filing and inaccurate return fines of arts. 53 and 54 for these documents (art. 55(1)).

• ΣΠΠ late, inaccurate or incomplete (art. 55(1)(α)). 1/1000 of the transactions that had to be documented, at least EUR 500 and at most EUR 2,000. A late amended ΣΠΠ is fined only if transaction amounts change and the total differences exceed EUR 200,000. For an inaccurate ΣΠΠ, the fine is worked out on the amounts affected and applies only if the inaccuracy exceeds 10% of the total transactions that had to be documented.
• ΣΠΠ not filed (art. 55(1)(β)). 1/1000 of the transactions that had to be documented, at least EUR 2,500 and at most EUR 10,000.
• File handed over late or never (art. 55(1)(γ)). Counting from the request: day 31 to 60, EUR 5,000; day 61 to 90, EUR 10,000; after day 90 or never, EUR 20,000.
• Country-by-country report (art. 56(α)). Not filed: EUR 20,000. Late or inaccurate: EUR 10,000. These replace the art. 55 fines.
• Tax on an adjustment (art. 54(1)). If an audit adjustment raises the tax due above the tax on the return, the fine is a share of the tax difference: 10% where the difference is 5% to 20% of the tax on the return, 25% where it is over 20% and up to 50%, and 50% where it is over 50%.
• Interest (art. 52(1)). Tax not paid on time carries interest from the day after the original payment deadline. After an audit assessment, interest runs from the date the tax should first have been paid. This skill does not state the interest rate (see "Not yet confirmed").

Cross-border points

• Permanent establishments. A Greek permanent establishment of a foreign business documents its dealings with its head office and with persons connected to the head office. A Greek company documents its dealings with its own permanent establishments abroad (ΚΦΔ art. 25(1)).
• APA (ΚΦΔ art. 26). Connected persons, Greek permanent establishments of foreign businesses (for dealings with head office and its connected persons) and Greek businesses' permanent establishments abroad may ask the AADE Governor to approve in advance the method for pricing specific future cross-border transactions with connected persons. The approval covers the method, comparables, adjustments and critical assumptions. A unilateral APA is decided within 18 months and never applies to earlier years. A bilateral or multilateral APA request may ask for the decision to apply to earlier years (a rollback), if the facts of those years match, the right to assess has not lapsed, and no audit order has been served for those years. An APA lasts at most 4 years. While its terms are kept, prices within it are treated as arm's length, and an audit only checks that the terms and assumptions still hold. It is revised if the critical assumptions prove wrong or change materially, or after a mutual agreement procedure under a treaty or the EU Arbitration Convention (art. 26(5)).
• Treaties. An adjustment abroad on a Greek company's counterparty does not reduce Greek tax under art. 50 by itself, since art. 50 can only increase Greek profit. Relief comes through the mutual agreement article of the treaty, which this skill does not cover in detail.
• Country-by-country reporting. Groups with consolidated revenue of EUR 750,000,000 or more report under art. 9ΑΑ of ν. 4170/2013 and AADE decision ΠΟΛ 1184/2017 as amended by Α.1341/2019, within 12 months of the end of the reporting year. Each Greek constituent entity files its notification electronically through the AADE application no later than the last day of the group's reporting fiscal year (ΠΟΛ 1184/2017 art. 2(3), as replaced by Α.1341/2019). Fines are in ΚΦΔ art. 56.
• Related rules elsewhere. The company exit tax (ΚΦΕ art. 66A) and withholding on outbound payments are in gr-cross-border. The withholding exemption for interest and royalties to associated EU companies (ΚΦΕ art. 63) is in gr-cross-border. The intra-group dividend exemption (ΚΦΕ art. 48) is not covered in this pack yet.

Worked examples

Example 1: does the company need a file, and what if the ΣΠΠ is late? (tax year 2026)

Alpha AE is a Greek company with turnover of EUR 12,000,000 in 2026. It buys goods from its 60% Italian parent for EUR 1,500,000 and pays the parent EUR 300,000 in service fees. Its connected transactions total EUR 1,800,000.

Turnover is over EUR 5,000,000, so the exemption limit is EUR 200,000 (ΚΦΔ art. 25(2)(β)). EUR 1,800,000 is over it, so Alpha keeps a documentation file and files a ΣΠΠ by 15 July 2027. If it files the ΣΠΠ late, the fine is 1/1000 of EUR 1,800,000, which is EUR 1,800. That sits between the EUR 500 floor and the EUR 2,000 cap, so the fine is EUR 1,800 (art. 55(1)(α)). If it never files, the same 1/1000 is EUR 1,800, which is below the EUR 2,500 floor, so the fine is EUR 2,500 (art. 55(1)(β)).

name: Alpha AE, file test and ΣΠΠ fines, 2026
inputs:
  turnover: 12000000
  goods_from_parent: 1500000
  service_fees_to_parent: 300000
  limit_high_turnover: 200000
steps:
  - connected_total: goods_from_parent + service_fees_to_parent
  - excess_over_limit: max(0, connected_total - limit_high_turnover)
  - base_fine: connected_total / 1000
  - late_spp_fine: clamp(base_fine, 500, 2000)
  - missing_spp_fine: clamp(base_fine, 2500, 10000)
expected:
  connected_total: 1800000
  excess_over_limit: 1600000
  base_fine: 1800
  late_spp_fine: 1800
  missing_spp_fine: 2500

Example 2: audit adjustment on a management fee, with a late file (tax year 2026)

Beta AE, a Greek company, declared corporate income tax of EUR 150,000 for 2026. It paid its parent a management fee of EUR 600,000. On audit, AADE accepts the client's own benchmark, which supports an arm's length fee of EUR 400,000, and adds the EUR 200,000 excess to Beta's profit under ΚΦΕ art. 50(1). Beta handed over its file on day 75 after AADE's request.

Extra tax is 22% of EUR 200,000, which is EUR 44,000. The difference is 44,000 / 150,000 = 29.33% of the declared tax. That is over 20% and up to 50%, so the inaccurate return fine is 25% of EUR 44,000, which is EUR 11,000 (ΚΦΔ art. 54(1)(β)). The file came in between day 61 and day 90, so a further EUR 10,000 fine applies (art. 55(1)(γ)). Total tax and fines: EUR 65,000, plus interest under art. 52 from the original payment deadline for the 2026 tax (not computed here). The parent's country may or may not give relief; that goes through the treaty's mutual agreement procedure.

name: Beta AE, management fee adjustment and late file, 2026
inputs:
  fee_paid: 600000
  arm_length_fee: 400000
  declared_tax: 150000
  cit_rate_pct: 22
  inaccuracy_fine_rate_pct: 25
  late_file_fine: 10000
steps:
  - adjustment: fee_paid - arm_length_fee
  - extra_tax: adjustment * cit_rate_pct / 100
  - difference_pct_of_declared: round(extra_tax / declared_tax * 100, 2)
  - inaccuracy_fine: extra_tax * inaccuracy_fine_rate_pct / 100
  - total_tax_and_fines: extra_tax + inaccuracy_fine + late_file_fine
expected:
  adjustment: 200000
  extra_tax: 44000
  difference_pct_of_declared: 29.33
  inaccuracy_fine: 11000
  total_tax_and_fines: 65000

Ask the client first

1. Who owns the company, directly and indirectly, and does anyone hold 33% or more of capital, votes or profit rights, or control it in practice? Are any owners spouses, parents or children of each other?
2. What was the company's turnover for the tax year? This sets the EUR 100,000 or EUR 200,000 limit.
3. What were all transactions with connected persons in the year, by type and amount, including loans, guarantees, management fees and any transfer of functions or staff?
4. Is the company part of a group with consolidated revenue of EUR 750,000,000 or more, and which entity files the country-by-country report?
5. Does the group already have a Master File, and is there an APA, an audit order or a foreign adjustment on these transactions?
6. Was the company set up under α.ν. 89/1967, or does it have permanent establishments abroad (or is it a Greek branch of a foreign company)?

Sources

Source	URL	Read on
Income Tax Code (ν. 4172/2013), Ministry of Finance codification up to ν. 5264/2025: arts. 2(στ) and 2(ζ), 50, 51, 58, 68, 72(84)	https://minfin.gov.gr/wp-content/uploads/2026/04/ΚΩΔΙΚΟΠΟΙΗΣΗ-ΤΟΥ-ΚΩΔΙΚΑ-ΦΟΡΟΛΟΓΙΑΣ-ΕΙΣΟΔΗΜΑΤΟΣ-ΜΕΧΡΙ-ΤΟ-Ν-5264-2025.pdf	2026-10-23
Ministry of Finance, notice of the Income Tax Code codification	https://minfin.gov.gr/koinopoiisi-kodikopoiisis-tou-kodika-forologias-eisodimatos-symfona-me-to-arthro-83-par-55-tou-n-5104-2024/	2026-10-23
Tax Procedure Code (ν. 5104/2024), AADE codification Ε.2109/2025 updated to ν. 5259/2025: arts. 25, 26, 52, 54, 55, 56, 83(29) and (30), and the old-to-new article correspondence table	https://www.aade.gr/sites/default/files/2025-12/e2109_2025.pdf	2026-10-23
AADE decision Α.1341/2019 amending ΠΟΛ 1184/2017 (country-by-country reports: pro rata threshold, 12-month deadline, notification deadline)	https://aade.gr/sites/default/files/2019-09/a1341_2019fek.pdf	2026-10-23
AADE, Ενδοομιλικές συναλλαγές (ΣΠΠ e-service, deadline, list of decisions: ΠΟΛ 1097/2014, ΠΟΛ 1144/2014)	https://www.aade.gr/endoomilikes-synallages	2026-10-23

Not yet confirmed: the content of the Master File, Local File and ΣΠΠ under ΠΟΛ 1097/2014 as amended by ΠΟΛ 1144/2014 (the decisions were identified but their text was not checked, so this skill does not list the file's contents or the ΣΠΠ fields); whether a newer decision under ΚΦΔ art. 83(29) replaced them; whether individuals carrying on a business are bound by art. 25, given that ΚΦΕ art. 50 names only legal persons and entities; the late payment interest rate under ΚΦΔ art. 52; any APA application fee; whether any AADE decision after Α.1341/2019 changed the country-by-country procedure; any 2026 law amending the Tax Procedure Code after ν. 5259/2025; the domestic rules implementing the EU dispute resolution directive 2017/1852.

Contributed by Ryan Duguid.