Our tax practice, led by our tax partner, Dr. George Naskaris provides, on a steady and recurrent basis, tax advice in respect of innovative and ground-braking transactions. Voted as the Greek Tax Firm of the Year for 2012 at the European Tax Awards, an institution organized by EUROMONEY and International Tax Review (ITR), our tax practice covers virtually all areas of taxation.
Over the years, our tax team has advised on the tax aspects of most of the corporate and financial transactions our firm has been involved in, as tax efficiency is one of the most important aspects of such transactions.
Our tax practice covers areas including:
● Corporate tax
● Property tax
● Investment funds and securities tax
● Employment tax
● Tax disputes
● Tax and estate planning
● Interpretation and implementation of Double Tax Treaties and the EU tax legislation
- Our Firm acted as the Greek legal advisor to Alpha Bank in connection with all matters of Greek law on the negotiating with the Greek and EU Institutions and regulatory authorities (SSM/DGComp and the ESM) its €2.55bn recapitalization. More specifically, since Alpha Bank was one of the four (4) systemic banks that had to be recapitalized pursuant to the new European Stability Mechanism Program it was asked by the authorities to complete an internal restructuring and prepare itself for the likelihood of being resolved in case it failed to raise the necessary recapitalization funds from the private sector.
- Advising Alpha Bank on the structuring and execution of the largest so far by a Greek bank Liability Management Exchange LME, by inviting for exchange holders of €1.1bn Senior Notes, Subordinated Notes and Hybrids. This LME transaction was extremely complicated as 27 different LME Securities, with different maturities, universe of investors, etc. were included in the exchange. Following two amendments of the terms of the LME Transaction in order to adjust it to the evolving market needs and developments of the New Recapitalization Framework, the LME Transaction was an unprecedented success as holders of LME Securities of €1.05bn accepted to exchange their LME Securities for new Alpha Bank shares.
- Advising Alpha Bank on the tax ascpets of the sale and transfer of the 97.3% of its listed subsidiary, Ionian Hilton Enterprises S.A. (“IHE”) for a consideration of Euro142mio. IHE is the owner of Hilton Athens, which is a prime asset Hotel in the city center. The Purchaser was chosen by Alpha Bank following an international bidding process, announced early in February, 2016.
- We advised Alpha Bank on update of its Euro30billion Euro Medium Term Programme, under which Alpha Bank and Alpha Credit Group PLC, the 100% UK subsidiary of Alpha Bank, issue notes in the international markets.
- Advised Alpha Bank on the tax aspects of the acquisition from Citibank/Greek Branch of its retail banking business and its credit card business. The project involved the combination of a sale of part of business and a sale of shares. In this context, Koutalidis Law Firm advised the purchaser on a wide range of matters concerning income tax, capital gains taxation, double tax treaty matters, value added tax (on the basis of Greek and EU law and the case law of the European Court of Justice), stamp duty, fiscal accounting, and tax filings.
- Our firm provided advice and legal assistance in all administrative and legal steps for the challenge of a fine imposed to a company by the competent tax authority for the alleged breach of the receipt of fictitious invoices. The company had to prove by all means that it acted in good faith and that the transactions in question were real. We note the case as important due to the wide range of the tax aspects that our firm had to deal with in the field of fines (specifically in respect of Code of Books and Records, V.A.T. and income tax) as well as regarding other possible administrative and penal sanctions
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