Tax

We have a fully comprehensive tax practice which advises private and public companies, partnerships and individuals, both on a standalone basis and as part of an integrated service across our transactional and disputes teams.

We identify, anticipate and deal with tax issues, risks and compliance arising in a business or private context. We have represented clients in relation to the amendment of adverse legislative provisions and submitted reports to the Ministry of Finance proposing legislative changes, with a focus on tax incentives for attracting foreign investors.

Corporate Advisory
We have extensive experience in advising on company structuring, operation, planning and policy, asset ownership, executive and employee remuneration and benefits from a tax perspective. Our aim is to provide innovative solutions to complex issues, such as mitigating regulatory risk and meeting challenges and to prepare our clients for legislative changes. Our practice works closely with correspondent law firms and advisors on cross-border structuring and liability, the effect of double taxation treaties and transfer pricing. We also advise on VAT and all other types of indirect taxes and the tax treatment of the provision of services and supply of goods.
Corporate Transactional
Our team provides highly technical advice on the tax structuring, planning and implementation of a wide variety of corporate transactions, including securities offerings, financings, cross border and local mergers and acquisitions, reorganisations, restructurings and insolvencies, as well as inward and outward investments. We place emphasis on factoring in the risks of prospective or retrospective changes to legislation which will affect the life of a transaction or investment. Many of the deals we advise on have a cross-border aspect or involve companies which are active globally, and we work with international advisors and law firms to meet the challenges such transactions present and assimilate the obligations of the countries involved. We also advise extensively on the direct and indirect tax aspects of the sale and purchase of real estate and other assets.
Investigations & Disputes
Our team has extensive experience in acting in tax controversy matters arising from liability to a wide variety of issues, including corporate and personal tax, indirect taxes, regulatory and legislative compliance, transfer pricing, tax adjustments and accounting, bad debt provisions, fund transfers abroad and debt to equity issues. We represent individuals, partnerships and corporations in investigations, audits and dawn raids, and before the Tax Authorities and Administrative Courts and in challenges to Tax Authority decisions, technical enquiries, applications for rebates and settlements of fines and tax bills.
Wealth & Estate Planning
Our team is highly experienced in advising individuals and families on wealth and estate planning, the protection of assets, cross-border and domestic estate administration, the implications of the implementation of the OECD Guidelines and EU Directives on exchange of information. We offer advice on personal tax liabilities, post-death planning, co-ownership of assets and establishing family offices. We have an expertise in wealth and succession planning, often developing innovative structures to enable our clients to make use of, transfer and eventually devolve their wealth. We also represent clients in high value tax and estate disputes.
Recent Experience
PIMCO Securitisation Tax and Duty Advice
We advised PIMCO on Greek tax and duty issues in connection with a portfolio of securitized receivables arising from electricity invoices in arrears (Zeus Portfolio) originated by Public Power Corporation (PPC).
Thomas Cook Liquidation Tax Aspects
We advised Alix Partners acting for Thomas Cook Group Tour Operations Limited in liquidation on the tax aspects of the sale of its shares in its English subsidiary Westfort Capital Limited (Target) to the other shareholder of the Target (being the Swiss entity LMEY Investments AG) and on the settlement of certain payment obligations of LMEY Investments AG towards TCGTO.
Tobacco Industry Tax Framework
During the pandemic in 2021 we advised an international tobacco company in relation to the tax and legal framework of the tobacco industry in Greece and on the new tax bill that amended the Greek Customs Code on Tobacco Smuggling issues.
€21m Tax Litigation
We are acting on behalf of the former CEO of a Greek Group of companies active in the medical industry before the Greek Administrative Court of Appeals in a dispute with the tax authorities regarding the assessment of additional income taxes and penalties in the amount of €21m.
UBO Advice
We advise a group of companies in relation to issues arising from the registration of ultimate beneficial owners.
US Fund Cross Border Loan
We are advising a US Fund on tax issues that may arise in Greece as a result of a cross border bond loan.
HNWIs Advice on Estates and Restructuring
We advise two high net worth individuals on family estates issues and on the tax restructuring of their UK Group of companies.
Car Manufacturer Entry to Electromobility Market
We advise a European car manufacturer in relation to tax and customs issues arising from its entry into the Greek electromobility market and launch of electric vehicles charging services in Greece.
Establishment of Foundation
We advised a high net worth individual on the establishment of a Foundation in Greece for charitable purposes.
Corporate Income Tax Dispute
We advise a construction company on profits distributions and successfully represented them in litigation arising from the imposition of corporate income tax on a special purpose tax reserve, involving an innovative method of calculation of the reserve, a dispute without precedent in Greece, as well as in the context of a tax audit.
UHNWIs Relocation Implications
We advised two ultra-high net worth individuals with dual citizenship on tax implications arising from their relocation to Greece under the special non-dom tax regime.
Source of Funds Declaration Advice
We are advising a leading Greek industrial company in relation to its obligation to submit source of funds declarations on behalf of certain BOD members.
Liechtenstein Foundation Advice
We advised two high net worth individuals on estates and inheritance tax issues including the separation of their estates and the liquidation and restructuring of a Liechtenstein foundation.
Customs Advice
We are advising one of Greece’s largest automobile importers and distributors in relation to customs legislation.
Tax Structuring Advice
We are advising a software company on cross-border tax structuring and VAT and corporate income issues.
€5.5m Tax Litigation
We are acting on behalf of the Greek representative of an Italian legal entity before the Greek Administrative Court of Appeals in a dispute with the tax authorities regarding the assessment of additional income taxes and penalties in the amount of €5.5m.
Customs Duties Dispute
We represented a leading distributor of luxury cars in relation to a customs duties dispute before the administrative courts and advised on stamp duties on loans within the framework of a tax audit, financial leasing and profits distribution.
Transfer of Assets to US Entities
We advised the managers of a high value estate on the restructuring of its assets in Greece by way of transfer to US legal entities.
Eurobank Tax Treatment of Non-Listed Bonds
We advised Eurobank Ergasias Services and Holdings SA and Eurobank SA on the tax treatment of non-listed bonds issued in Greece and outside the EU in the context of the establishment of a €5bn Programme for the Issuance of Debt Instruments and their listing on the Luxembourg Stock Exchange.
Tax Treatment of Stock Options and Shares
We advised a Swedish law firm in relation to the tax treatment of stock options and stock shares in Greece.
Recognitions