Greece Transfer Pricing Documentation Requirements
Greece requires a transfer pricing documentation file once intra-group transactions pass value thresholds geared to the company's gross revenue, and a Summary Information Table is filed electronically with the corporate tax return. The documentation file is produced within 30 days of a request during an audit.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
TP documentation Required | Intra-group transactions > EUR 100,000 (revenue ≤ EUR 5m) or > EUR 200,000 (revenue > EUR 5m) | By tax return due date | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 30 days. | EL | Yes (EUR 5,000 to EUR 20,000 by length of delay) |
Summary Information Table Annual filing | Companies maintaining a documentation file | By the corporate tax return deadline | Submission deadline The documentation must be filed with the tax authority by the date shown. | EL | Yes (EUR 2,500 to EUR 10,000 for non-filing) |
CbC report Required | Group revenue ≥ EUR 750m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
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Scope of the documentation obligation
A Greek enterprise must maintain a transfer pricing documentation file where its intra-group transactions with associated enterprises exceed a value threshold geared to its size. The threshold is EUR 100,000 in total where the company’s gross revenue for the year does not exceed EUR 5 million, rising to EUR 200,000 in total where gross revenue exceeds EUR 5 million. The documentation file is produced within 30 days of a request during a tax audit. A formal Master File and Local File structure is anticipated, but the operative obligation is the documentation file described here.
Distinctive features of the Greek regime
The distinctive feature of the Greek regime is the Summary Information Table filed alongside the documentation file. Companies must submit this table electronically up to the deadline for the corporate tax return, and it carries its own penalty regime separate from that for the documentation file itself. Late submission or non-submission of the documentation file on audit attracts a penalty of EUR 5,000 to EUR 20,000 graded by the length of the delay, while failures connected with the Summary Information Table run from EUR 2,500 to EUR 10,000, calculated by reference to the value of the transactions concerned. There are no safe harbour rules.
Benchmarking and comparables
Any database may be used for the comparable search provided the relevant details are recorded in the documentation file, and pan-European studies are accepted in practice, although where the Greek entity is the tested party the feasibility of a local Greek search should be checked. Where a profit-based method is used, Greek law requires the weighted-average financial data of the comparables for the three years preceding the year under review, while the tested party’s result must refer to a single year. A benchmarking study may be used for the following two financial years, with the financial data updated annually and the comparability and independence of the final set re-examined each year. The limitation period is, in principle, six years following the year-end.
Frequently asked questions
What transaction value triggers a Greek documentation file?
Intra-group transactions exceeding EUR 100,000 in total where the company's gross revenue is EUR 5 million or below, or EUR 200,000 in total where gross revenue exceeds EUR 5 million.
Does Greece require any annual transfer pricing filing?
Yes. A Summary Information Table must be submitted electronically up to the deadline for the corporate tax return, with its own penalty regime for non-filing or late or inaccurate filing.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.