Katerina Stathakarou

23 Jul 2024 | in ARTICLES, Corporate law, by and

Adoption of restrictions with regard to Disqualified Directors – Law 5122/2024

By virtue of Law 5122/2024, the provisions of Directive (EU) 2019/1151 relating to “disqualified directors” were transposed in Greek legislation. The newly adopted measures aim to prevent fraudulent or other abusive behavior by refusing the appointment of a person as a director of a company, taking into account the former conduct of that person in their own territory, as well as on the basis of information provided from other Member States. READ FULL ARTICLE

04 Apr 2024 | in ARTICLES, Tax law, by

Artificial arrangement spotted by the Dispute Resolution Directorate: The establishment of a shell company in Bulgaria

The tax audit authorities recently examined the establishment of a company in Bulgaria through the general anti-avoidance rule and confirmed that an artificial arrangement had taken place, with the sole purpose of reducing tax burdens. The entrepreneur challenged the tax findings before the Dispute Resolution Directorate, however all arguments raised were confuted and Greek tax was imposed on the revenues generated from the Bulgarian company. READ FULL ARTICLE

23 Nov 2023 | in ARTICLES, Tax law, by

New Decision of the Independent Authority for Public Revenue (IAPR) Links Tax and Business Registries (in Greek)

On October 10, 2023, the Independent Authority for Public Revenue (IAPR) published Decision 1151/2023 for the interconnection of the Tax and Business Registries. From 11 October 2023, the IAPR registry will be automatically updated in relation to a number of company changes of Sociétés Anonymes registered in the General Commercial Registry (GEMI). This article offers an overview of the aforementioned Decision and its impact on data integration. 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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