Georgios Minoudis

Taxation of income from real estate in Greece, where the beneficiary is a foreign legal person or entity

In his insightful article, originally featured in the October 2024 issue of the digital journal “Epixeirisi” by Nomiki Bibliothiki, our Partner, Georgios Minoudis, comments on the current approach of the Greek Tax Authorities regarding the taxation of income from real estate in Greece, where the beneficiary is a foreign legal entity or entity, highlighting some potential difficulties the current approach may entail. READ FULL ARTICLE

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

Shell companies – recent decisions by the Greek Dispute Resolution Directorate (in Greek)

Increasingly, the tax authorities and the Dispute Resolution Directorate (“DRD”) are identifying artificial arrangements aiming to solely obtain tax benefits. Such is the case of a shell company in Bulgaria, which was established as an artificial vehicle to take advantage of the much more favorable Bulgarian income tax rate (DRD decisions No. 1989 and 3167/2022). READ FULL ARTICLE

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