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4.3. Branch Profit (Deemed Remittance) Tax

A branch profit remittance tax applied at the rate of 10% as the remittance of after tax profits by a PE was assimilated to a dividend distribution and subject to withholding tax at the same rate as dividend distributions. The new Tax Code (Law 4172/2013 of 23 July 2013) is interpreted as having abolished this tax effective from 1 January 2014. This position has now been confirmed by an administrative decision (POL 1042/2015) issued by the Tax Administration to the effect that the remittance of after tax profits by the Greek PE of a non-resident company to its foreign head office is no longer assimilated to a dividend distribution and, therefore, no longer attracts a withholding tax.