A Greek motor vehicle wholesale company was assessed additional income tax after authorities excluded comparable companies and adjusted results to the arm's length median, converting declared losses into taxable profits. The Administrative Court of Appeal upheld the adjustments, but Greece's Supreme Administrative Court reversed the decision in 2025, finding the lower court had incorrectly relied on a ministerial decision not applicable to the years under review ... Read more

A Greek motor vehicle wholesale company was assessed additional income tax after authorities excluded comparable companies and adjusted results to the arm's length median, converting declared losses into taxable profits. The Administrative Court of Appeal upheld the adjustments, but Greece's Supreme Administrative Court reversed the decision in 2025, finding the lower court had incorrectly relied on a ministerial decision not applicable to the years under review ... Read more

FCA Greece S.A., a car importer, reported a tax loss for 2011 using TNMM-based transfer pricing documentation. Greek tax authorities rejected comparables and adjusted results to the interquartile range median, issuing a €6.5 million correction. The Supreme Administrative Court upheld the lower court's annulment, confirming that adjustment to the median without specific justification is unlawful where results already fall within the arm's length range ... Read more

A Greek motorcycle wholesaler challenged a tax authority adjustment that moved its tested operating margin to the median of a recalculated interquartile range for 2008. The Supreme Administrative Court ruled in favour of the taxpayer, finding that the 2008 legal framework created only a rebuttable presumption and that newly enacted transfer pricing rules could not be applied retroactively as a binding methodology for that year ... Read more

A Greek retailer deducted royalties for trademarks and know-how and management service fees paid to a Dutch affiliate. The tax authority disallowed both, citing vague contracts, lack of proven benefit, and a flawed CUP study that ignored internal licensing comparables. The Administrative Tribunal upheld the assessment in April 2025, finding the documentation inadequate and the transfer pricing study non-compliant with OECD Guidelines ... Read more

A Greek company appealed the disallowance of intra-group management service fees deducted in its 2013 taxable profits. The company argued the tax authority had improperly shifted the burden of proof. Greece's Supreme Administrative Court rejected the appeal in 2025, ruling that the burden of proving deductibility rested with the taxpayer and that the invoices, contracts, and supporting documents lacked sufficient specificity to establish a genuine link to business activity ... Read more

A Greek company sought to deduct management service fees paid to group entities, but the tax authority disallowed the expenses due to vague contracts and insufficient documentation. The Administrative Court of Appeal upheld the assessment, finding the company had not proven the services were actually rendered or served its business needs. In March 2025, the Greek Supreme Administrative Court dismissed the company's appeal, confirming the fees were correctly treated as non-deductible ... Read more

A Greek dairy distributor paid royalties to a related Dutch entity for trademark and know-how licences, with payments expanding after a 2018 restructuring to full-risk distributor status. The Greek tax authority disallowed the additional deductions, finding the payments lacked arm's length support and conferred no distinct benefit, as the company already held the expertise to sell the products. The Administrative Tribunal upheld the authority's position in February 2025 ... Read more

A Greek elevator company used TNMM for related-party sales, but the tax authority substituted a cost plus method using internal third-party comparables, raising taxable income. The Administrative Court largely upheld the authority's approach in 2024, finding internal comparables reliable after adjustments. However, it annulled the adjustment for sales to a Turkish affiliate, ruling that market differences and a market-penetration strategy made those sales incomparable to Swedish or Czech transactions ... Read more

TYRAS S.A., a Greek dairy producer, was assessed additional taxable income after the tax authority found non-compliance with the arm's length principle on intra-group transactions. The company argued the discrepancy was negligible at 0.17% and that OECD guidelines had been followed. The Administrative Court found mostly in the taxpayer's favour, and Greece's Supreme Administrative Court dismissed the tax authority's subsequent appeal in September 2024 ... Read more

A Greek IT equipment trader had €22.4 million in purchase expenses disallowed by the tax authority because goods were invoiced through its Cyprus-based parent under a preferential tax regime, despite being delivered directly by Cisco and Intel. The tax authority treated these as triangular transactions and denied deductions. Greece's Supreme Administrative Court ruled in favour of the taxpayer in May 2024 ... Read more

A Greek subsidiary of a global electronics group applied the TNMM method using ROS as its profit level indicator to document intra-group goods transactions for 2018. The tax authority rejected six of ten comparables as insufficiently comparable, conducted its own benchmark, and adjusted the taxpayer's income to the median of the interquartile range. The Administrative Tribunal upheld the assessment in May 2024, rejecting the taxpayer's claim of misapplication of the transfer pricing method ... Read more

A Greek foreign exchange services company granted loans to a related party in FY 2018 and 2019 but failed to submit transfer pricing documentation when requested during a tax audit. The Greek Administrative Tribunal upheld fines imposed by the tax authority and confirmed the disallowance of inadequately documented cost deductions, rejecting the taxpayer's appeal in full in May 2024 ... Read more

A Greek company applied an 8.5% interest rate on €18.5 million in related-party loans using the CUP method with stand-alone credit comparables. The tax authority reduced the rate to 2.92%, finding that implicit group support enhanced the company's creditworthiness. The Administrative Tribunal upheld the assessment in 2024, confirming that group membership and implicit support must be reflected when determining the arm's length interest rate ... Read more

A Greek company challenged a tax authority assessment covering intra-group sales and purchases in FY 2018 and 2019, arguing the transfer pricing method had been misapplied. The Dispute Resolution Board disagreed, upholding the assessment and confirming that internal comparables — transactions with independent third parties — were more reliable than external benchmarks under OECD Guidelines, given identical accounting practices and a closer relationship to the controlled transactions ... Read more

A Greek company received an intra-group loan to repay outstanding dividends to its shareholders. The tax authority disallowed the interest deduction, finding the loan served shareholder interests rather than generating company income. The Administrative Court and Court of Appeal both dismissed the taxpayer's challenge. In 2023, the Greek Supreme Administrative Court upheld those decisions, confirming the interest expenses failed the business benefit test under Article 22 of Law No. 4172/2013 ... Read more

Following a tax audit, Greek authorities disallowed deductions claimed by Intralot S.A. for intra-group services provided by its related Cyprus entity, Intralot International Ltd., on the basis that valid invoices were absent. The Administrative Court of Appeal upheld the disallowance. Greece's Supreme Administrative Court allowed the appeal in 2023, finding the lower court had incorrectly applied VAT invoicing rules to assess deductibility, and remanded the case for further examination ... Read more

A Greek company entered a bond loan with related parties at an 8.1% interest rate, determined using external CUP comparables. The tax authority applied an internal CUP, adjusting a third-party bank rate of 2.03% by a 2% parent guarantee fee to arrive at a 4.03% arm's length rate. The Administrative Tribunal upheld the assessment in 2023, confirming the authority's methodology as consistent with OECD Guidelines ... Read more

A Greek company was audited for FY2016 and 2017, with tax authorities rejecting deductions for excessive waste material costs and applying the CUP method instead of TNMM to intra-group sales. The adjustment produced approximately €392,000 in additional income. The Dispute Resolution Board upheld both the denied deductions and the transfer pricing adjustment in full, ruling in favour of the tax authority in November 2022 ... Read more

A Greek pharmaceutical distributor applied the resale price method for its intra-group sales and service activities, but the tax authorities rejected this in favour of TNMM and issued an additional taxable income assessment. The Administrative Tribunal largely upheld the assessment for sales activities, finding the company's net profit margin fell outside the interquartile range, but annulled the adjustment for service activities where remuneration was within the arm's length range ... Read more

A Greek clothing distributor challenged a transfer pricing assessment issued following a tax authority audit concluding its remuneration was not arm's length. The Greek Administrative Tribunal dismissed the appeal in June 2022, upholding the upward taxable income adjustment and confirming the audit findings as valid, acceptable, and fully justified ... Read more

A Greek company challenged a tax authority assessment that disallowed deductions for intra-group services and adjusted VAT accordingly following an audit. The company appealed, arguing the adjustment was unwarranted. The Administrative Tribunal upheld the tax authority's assessment in full, confirming that the intra-group services failed to meet the benefit test and that the resulting VAT adjustment was correct ... Read more

A Greek marine fuel company was audited for FY 2015, with tax authorities rejecting its chosen CUP method and applying TNMM instead, resulting in an upward transfer pricing adjustment. The company challenged the assessment before the Dispute Settlement Board, which dismissed the complaint and upheld the tax authority's position, confirming that TNMM was the more appropriate method for the transactions under review ... Read more

A Greek company challenged a €1.26 million tax assessment for FY 2017 covering transfer pricing adjustments on intra-group loan interest rates, royalty payments, management fees, and losses on share disposals. The tax authority argued the share transactions lacked commercial substance and were used to indirectly write off unrecoverable debts. The Administrative Tribunal dismissed the appeal and upheld the assessment in full, ruling in favour of the tax authority ... Read more

A Greek dairy distributor was audited by the tax authorities, who determined that prices paid to related parties in FY 2017 exceeded the arm's length range and issued an upward taxable income adjustment. The company appealed, but the Administrative Tribunal dismissed the appeal in November 2021, fully upholding the tax authority's assessment and confirming the transfer pricing methodology applied ... Read more

A Greek company applied the CUP method in its transfer pricing documentation, but tax authorities rejected this and issued an upward adjustment using the cost-plus method. The company appealed, and the Administrative Tribunal sided largely with the taxpayer, setting aside the assessment on the grounds that the authorities failed to provide clear, specific, and adequate reasoning for departing from the company's chosen transfer pricing method ... Read more

A Cypriot company provided interest-free loans to an affiliated Greek entity. Following an audit, Greek tax authorities issued an upward adjustment to taxable income, applying the CUP method and benchmarking against domestic bank lending rates. The Administrative Tribunal dismissed the taxpayer's appeal in 2021, confirming that the absence of interest did not comply with the arm's length principle ... Read more

A Greek company paid a foreign group manufacturer above arm's length prices for limited risk manufacturing services. Following an audit, Greek tax authorities issued an upward taxable income adjustment. The Administrative Tribunal dismissed X Ltd.'s appeal in May 2021, confirming the audit findings were valid, thorough, and fully substantiated, ruling mostly in favour of the tax authority ... Read more

A Greek pharmaceutical distributor buying exclusively from affiliates reported losses for 17 consecutive years. The tax authority applied the TNMM, arguing a limited risk distributor should earn a small guaranteed positive return. The Administrative Tribunal dismissed the company's appeal in 2020, upholding the assessment and confirming the arm's length range calculations and comparable company selection methodology used by the tax authority ... Read more

A Greek agricultural machinery group priced intercompany sales to its German distributor using TNMM with itself as the tested party. The Greek tax authority recharacterised the transactions, applying a cost-plus method with the German subsidiary as tested party. The Administrative Tribunal upheld the revised assessment in 2020, finding the authority's method selection lawful, justified, and fully documented, dismissing the taxpayer's appeal as unfounded ... Read more

A Greek pharmaceutical equipment wholesaler was assessed by tax authorities for allegedly fictitious costs deducted in FY 2009, linked to a Cyprus-based sole supplier. The Greek Supreme Administrative Court, in May 2020, found mostly in favour of the taxpayer, setting aside significant portions of the assessment and fine, and remanding the case for reexamination on burden of proof and anti-avoidance grounds ... Read more

The Greek tax authorities challenged BMW Hellas S.A.'s pricing of imported vehicles, issuing a customs valuation adjustment following an audit. The Administrative Court of Appeal annulled the adjustment, and the tax authorities appealed. In April 2020, the Greek Supreme Administrative Court dismissed the appeal, confirming that importing vehicles at manufacturer list prices, even if lower than prior import prices, does not constitute customs fraud or smuggling ... Read more

A Greek company borrowed from a related party to fund dividend payments to its shareholders. The tax authority disallowed the interest deductions, finding the loan did not serve the company's business or generate income. The Administrative Tribunal dismissed the taxpayer's appeal in March 2020, confirming that interest on loans used solely to discharge dividend obligations is non-deductible under Greek income tax law ... Read more

Greek tax authorities issued a transfer pricing adjustment for FY 2013 after exceeding the 18-month audit completion deadline set under POL. 1159/2011. The taxpayer appealed, and Greece's Supreme Administrative Court ruled in its favour, finding the assessment time-barred. The court held that failure to complete the audit within 18 months rendered the case definitively closed, with re-inspection only permitted within the standard five-year period for serious offences ... Read more

A Greek shareholder transferred vehicle scrapping rights to its wholly owned subsidiary, VSR Inc, at below-cost prices to reduce overall taxation. The tax authority found the transactions lacked economic substance and constituted artificial arrangements inconsistent with normal business behaviour, issuing revised assessments and substantial penalties. The Administrative Tribunal dismissed VSR's appeal in December 2019, ruling entirely in favour of the tax authority ... Read more

A Greek company provided an interest-free loan to its sole shareholder and argued it had no expectation of profit as it was not a bank. The tax authority assessed additional interest income based on Bank of Greece reference rates. The Administrative Tribunal dismissed the company's appeal in 2019, confirming that the related-party loan breached arm's length principles under Article 50 of Law 4172/2013 ... Read more

A Greek administrative tribunal ruled mostly in favour of the tax authority after an audit found that a Cyprus Corp had overpriced mechanical and medical equipment sold to its Greek affiliate by nearly 3.8 million euros in 2011. The arrangement inflated Greek depreciation deductions while keeping profits in low-tax Cyprus. The court confirmed the transfer pricing adjustment and associated penalties, citing direct common ownership and control between the two entities ... Read more

A Greek company purchased mechanical and medical equipment from a related Cyprus entity at inflated prices, overstating Greek depreciation deductions while shifting profits to the lower-tax Cyprus jurisdiction. Following an audit of FY 2011, Greek tax authorities issued a revised assessment disallowing €3.69M of the €5.95M purchase price. The Administrative Tribunal ruled predominantly in favour of the tax authority in January 2018 ... Read more