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Greece Abolishes Special Solidarity Contribution in 2023 and Introduces New Corresponding Adjustment Provisions for Transfer Pricing — Orbitax Tax News & Alerts

Greece published Law No. 4972/2022 in the Official Gazette on 23 September 2022, which contains various measures including certain tax measures. One of the main measures is the repeal of the special solidarity contribution on individuals for all income from 1 January 2023. The repeal is provided through the amendment of a prior provision that extended the suspension of the contribution for employment income in the private sector in 2022.

Another important measure amends an existing provision on transfer pricing upward adjustments to provide for corresponding downward adjustments. It is provided that if, following an audit, the taxable profits of a legal entity/person taxable in Greece are adjusted upward according to the arm's length principle, and such profits have also been included in the taxable profits of a related legal entity/person, then such related legal entity/person may request a corresponding downward adjustment. For this purpose, the related legal entity/person must request the adjustment by submitting an amended tax return along with the notification of the relevant audit report. The amended tax return and notification of the relevant audit report must be submitted within three months from the notification of adjustment for the first-mentioned legal entity/person. This measure is generally effective from 23 September 2022.

Click the following for a copy of Law No. 4972/2022 as published by a third party.