Eleonora Ligoutsikou

01 Sep 2025 | in ARTICLES, Tax law, by

Observations on CJEU Case C-228/24, Judgment of 3 April 2025 – New Interpretative Tools for the Application of the Anti-Abuse Rule under the Parent-Subsidiary Directive (2011/96/EU)

In Nordcurrent group UAB (C-228/24), referred by the Lithuanian Tax Disputes Commission, the Court of Justice of the European Union revisited the scope of the anti-abuse rule enshrined in Article 1(2)–(3) of the Parent-Subsidiary Directive (2011/96/EU). Drawing on its landmark rulings in T Danmark and Y Denmark ApS (C-116/16 and C-117/16), the Court elaborated on the circumstances under which a corporate arrangement must be deemed non-genuine and on the definition of a tax advantage that runs counter to the purpose of the Directive. The judgment ultimately held that, on the facts at hand, no abusive use of the Directive’s... READ FULL ARTICLE

04 Jun 2025 | in ARTICLES, Corporate law, by and

Amendments of Greek Development Law – Key Reforms

On June 2nd, Law 5203/2025 was enacted, restructuring and amending the existing Development Law 4887/2022. The amendment introduces several key changes, including the establishment of new aid schemes alongside the revision or abolition of existing ones, the introduction of a fast-track licensing incentive and a loan guarantee incentive under specific schemes, the enhancement of evaluation and audit mechanisms for investment plans, and the simplification of operations of collective administrative bodies involved in various procedural stages. In our latest article, you may find an enlightening overview of the recent changes. READ FULL ARTICLE

07 Aug 2024 | in ARTICLES, Tax law, by

The New Tax Procedure Code: A Comparative Study of the Significant Changes Enacted by Law 5104/2024 (in Greek)

Law 5104/2024 aims to modernize tax processes, introducing digital communication between taxpayers and authorities, and automating annual returns for individuals; it updates deadlines for submissions and revises audit initiation criteria; it also adds a new basis for extending the 5-year statute of limitations. This article explores these and other changes, providing detailed descriptions and commentary on their potential implications and effects. READ FULL ARTICLE

15 May 2024 | in ARTICLES, Tax law, by and

Formation of the price of shares acquired by natural persons according to art. 42 of the Income Tax Code (ITC) and circulars E.2171/2021 and E.2016/2024 – A brief commentary

A different treatment referring to the formation of share acquisition price by natural persons is reserved to shares originating from the capitalization of premium as opposed to shares originating from the capitalization of profits. The article, which has been originally published in the digital journal “Epixeirisi” issued by Nomiki Bibliothiki (issue 4/2024) demonstrates the differences through practical examples and discusses whether such treatment is justified. READ FULL ARTICLE

17 Oct 2022 | in ARTICLES, Tax law, by and

Share capital increase of a sole shareholder S.A.- a tax avoidance case (in Greek)

An arrangement set by a sole shareholder S.A. was declared artificial by the tax auditors, as its main purpose was to avoid paying the capital concentration tax corresponding to such a transaction. The tax authority invoked article 38 of Law 4174/2013 (general anti-abuse rule) and ignored the arrangement, thus imposing the correct capital concentration tax and accompanying penalties, whereas the Dispute Resolution Directorate confirmed the audit findings (decision No. 2746/2022). READ FULL ARTICLE

04 Jul 2022 | in ARTICLES, Tax law, by , and

Capitalisation of debt and subsequent sale of resulting shares at a loss amounts to an artificial arrangement

The Dispute Resolution Directorate of the Independent Authority for Public Revenue in its decision No. 4450/2021 held that where a creditor to a company capitalised the debts becoming a shreholder and then immediately sold the shares under their par value, the resulting loss is not tax deductible. READ FULL ARTICLE

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