Tax

Tax is a diverse and fast-changing environment in Greece, presenting special challenges. Policy changes, in an effort to maintain and increase tax revenue, and a tax administration trying to move towards efficiency and modernization are complemented by constant changes in the EU and international tax environment. Our highly experienced team, comprising of senior professionals with a wide degree of domestic and international experience, can effectively navigate through uncertainty, identifying issues, and present solutions that mitigate tax risks, while ensuring compliance.

Our tax practice, provides, on a steady and recurrent basis, tax advice in respect of innovative and ground-braking transactions. Koutalidis Law Firm was 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), following the landmark case of the Euro 206 billion Private Sector Involvement (PSI) Programme of the Hellenic Republic for the restructuring of its sovereign debt where Koutalidis Law Firm acted as the Greek Tax Law advisor of the Dealer Managers.

We provide legal advice in respect of all areas of taxation and tax issues, whether domestic or cross border, in a corporate or private context, standalone or as part of a multidisciplinary team. Our team has a deep and thorough understanding of the Greek tax system and tax critical considerations and, above all, offers a forward-thinking approach that can shield our clients against a challenging environment and achieve optimal outcomes.     

Services

Banking, Finance and Capital Markets

Our team is among the leaders in all tax aspects relating to Banking & Finance, ranging from the traditional Banking & Finance transactions to leveraged buy-outs, bank recapitalizations, NPL portfolio sales and other securitizations, as well as sovereign and corporate debt restructuring.

Project Finance

Our team has solid experience in all tax aspects relating to Project Finance, having advised a wide range of businesses on the structure of their domestic and cross border transactions. We have traditionally advised on tax related issues of most of the major Greek project financing deals, representing domestic as well as foreign financial institutions, in all stages of project financing, securitizations and structured products, both on the lenders’ and on the borrowers’ side.

Business Reorganizations

We advise on all tax aspects of domestic and cross-border mergers and acquisitions, spin-offs, demergers, as well as all related transactions, including joint ventures, holding company and financing structures. Our tax team has very high expertise and focus on tax incentive legislation for business reorganisations, business restructurings and corporate transformations, including incentives for mergers and acquisitions (M&A), and offers solutions for tax efficient transactions, to maximize value, also providing support after completion of the transaction.

Corporate

Our tax team advises on all aspects of domestic and international business taxation matters, including the establishment of branches or subsidiaries and the support in operations and transactions. We offer a unique forward-looking approach; assisting in tax compliance and the assessment of tax risks, while focusing on Tax Law changes affecting the course of business.

Cross-border Dispute Resolution

Situations in which different States differently interpret or apply the provisions of bilateral tax agreements and conventions can create serious tax obstacles for businesses operating across borders, often leading to double taxation. Our firm has significant expertise in handling mutual agreement procedure (MAP) cases, under the double treaty and the Arbitration Convention MAP mechanisms, recently complemented by the new EU Directive on tax dispute resolution.

High Net Worth Individuals

Our team has extensive and long lasting experience in supporting high-net-worth individuals on all tax aspects of their professional and private lives, including all tax residence matters, executive compensation schemes, gift and inheritance taxation, tax audits and litigation. Most recently, we have been actively supporting a number of foreign individuals seeking to enter the alternative taxation regimes for individuals, professionals and pensioners.

International Tax

Our team consists of highly skilled experts on all EU and international tax issues, focusing on EU Tax Law, tax treaties, anti-avoidance rules and disclosure obligations, with a wide experience in handling permanent establishment issues. We offer integrated solutions as to the structuring of complex transactions, including cross-border investments, while ensuring compliance.

Investment Funds

Our tax team regularly advises a wide range of investment funds, including private equity funds, real estate funds as well as alternative investment funds and fund managers, offering our expertise both to the funds side and to prospective investors. 

Real Estate

We offer high quality tax advice on all varieties of real estate transactions, both for corporations and individuals, including real estate transactions tax, real estate holding tax and property tax. An area of particular focus is the Special Real Estate Tax (SRET), which has proven to be a very important factor as regards the tax structuring of all major real estate projects in Greece.

Tax Controversy and Litigation

Our team successfully supports corporate and individual clients in all stages of tax audits, providing an accurate estimate of the tax position, and supporting communication with the tax authority, including drafting technical enquiries, for the effective resolution of the dispute. We have an impressive success rate before the tax authority, in the administrative dispute resolution stage, as well as before administrative Courts of all instances with respect to corporate and individual income taxation, fiscal accounting, indirect taxes and tax residence.

Our work also focuses on voluntary disclosure issues and tax penalties. Importantly, we offer unique expertise in the application of general and specific anti-avoidance provisions.

VAT and Indirect Taxes

Our team has very deep knowledge and understanding of the Greek system of indirect taxes and successfully advises on the best strategy to mitigate indirect tax costs and risks. We provide advice on VAT and indirect taxes issues in all kinds of transactions, including intra-community and cross-border provision of goods and services, digital economy, VAT refunds, VAT compliance and permanent establishment related matters. Other areas of particular focus include, indicatively, the stamp duty legislation, which is an important factor to investment structuring, as well as the bank levy of L. 128, which significantly affects loans and credit from financial institutions.

Wealth and Estate Planning

Our team has successfully provided expert advice to the most prominent Greek individuals and families on any aspect of wealth and estate planning, including the smooth succession of family businesses. Our services include, among others, cross-border and domestic estate and income tax planning and compliance, succession planning, gift and inheritance taxes, purchases, sales and structuring for asset protection, as well as family offices and tax residence matters.

View Practice Highlights

Our awarded tax services have come as a result of advising in some major cases.

  • The Joint Lead Managers in respect of the issuance by the Hellenic Republic of €3,000,000,000, 1.50 per cent Notes due 2030
  • Eurobank Ergasias S.A. with regards to the sale of 80% of the share capital of its subsidiary Eurobank Financial Planning Services to doValue S.p.A.
  • The 4 Greek systemic banks (Alpha Bank, Eurobank, the National Bank of Greece and Piraeus Bank) on their entry into an innovative and ground-breaking servicing agreement (SLA) with Italian credit institution doBank S.p.A.
  • Piraeus Bank S.A., Piraeus Leasing S.A. and Piraeus Leases S.A. on the joint sale of their NPL portfolios equivalent to c. €1,682 million of legal claims
  • A syndicate of Greek Banks on Greek Tax Law matters in connection with an up to €100m bond issue by Athens International Airport S.A. for the financing of five construction projects
  • Alpha Bank S.A. on matters of Greek Tax Law on the successful direct issuance of a landmark Euro 500 million Tier 2 subordinated bond
  • The Joint Lead Managers of the Hellenic Republic’s issuance of €2,500,000,000, 1.875 per cent Notes due 2035, on the terms and conditions set out in the offering circular prepared by the Republic and dated 31st January 2020, on matters of Greek Tax Law
  • A consortium of banks led by Goldman Sachs and Credit Suisse on matters of Greek Tax Law in connection with a €500m fixed rate unsecured bond issue and tender for notes purchase​ launched by Hellenic Petroleum
  • A consortium of banks led by Goldman Sachs and JP Morgan on matters of Greek Tax Law in connection with a €525m high yield bond issue by the WIND Hellas group and the signing of a new €75m revolving credit facility
  • The sellers, including the investment fund Southbridge Europe Mezzanine, on matters of Greek Tax Law in connection with the sale of Arivia group to Upfield
  • A Swedish multinational group, currently a global leader in the home and business appliance industry, in relation to the Greek Tax Law aspects of the group restructuring which involved separation and transfer of functions and assets and completed in September 2019
  • The Joint Lead Managers of the Hellenic Republic’s issuance of €2,500,000,000, 1.875 per cent Notes due 2026, on the terms and conditions set out in the offering circular prepared by the Republic and dated 19th of July, 2019, on matters of Greek Tax Law
  • Deutsche Bank AG, BNP Paribas and HSBC as Dealer Managers in the €206bn Private Sector Involvement (PSI) Programme of the Hellenic Republic for the restructuring of its sovereign debt; the largest sovereign debt restructuring up to date
  • Deutsche Bank AG on the Greek shares sale tax and capital gains tax upon a change of depositary or cancellation of DRs in a Depositary Receipt program; resulted to a change of relevant HELEX rules
  • Alpha Bank on the tax aspects of the sale and transfer of the 97.3% of its listed subsidiary, Ionian Hilton Enterprises S.A. (“IHE”) for a consideration of Euro 142 mio with respect to the sale of the Hilton hotel
  • Aegean Airlines, GE Capital Aviation on aviation Tax Law
  • Alpha Bank on the tax aspects of its 2015 €2.55bn recapitalization
  • Alpha Bank on the tax aspects of 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
  • Alpha Bank on the update of its Euro 30 billion 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
  • Alpha Bank in respect of the acquisition of the Citibank Greek retail banking and credit card business
  • Τhe Finance Parties, represented by Credit Agricole, and Aegean Motorway S.A., on tax matters in connection with the €1.3bn Project Reset Documents for the Maliakos-Kleidi motorway
  • Hochtief AG on the tax matters for the disinvestment from the Athens International Airport S.A.;
  • Credit Suisse, UBS, HSBC, BNP Paribas and Wilmington Trust on the offering by S&B of €275 mio 9.25% Senior Secured Notes;
  • Credit Agricole in selling its controlling interest in Emporiki Bank to Alpha Bank in a €4bn transaction.

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