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Transfer pricing rules changed


Taxand Greece highlights changes to the rules which apply to transfer pricing documentation.

The new legal framework is influenced by international developments in the field of transfer pricing, including the OECD Report on Transfer Pricing Documentation and country‐by‐country reportng published upon completion of Action 13 of the OECD/G20 Base Erosion and Profit Shifting Project.

These changes to documentation include:

  • Information about the group, provided in the first part of the transfer pricing file, should contain information on (i) the group’s intercompany financial activities, (ii) changes in the ownership of intangibles across the group and (iii) the group’s tax position
  • Special reference should be made to the documentation of transactions concerning intra‐group business restructurings and transfer of intangibles
  • Enterprises should justify transfer pricing year‐end adjustments in the context otheir annual transfer pricing file
  • Additional information should be provided in relation to intra‐group transactions performed between Greek enterprises and associated enterprises tax resident in non‐cooperative tax regimes; information includes the financial position of the associated enterprise

Discover more: Transfer pricing documentation rules

Your Taxand contact for further queries is:
Yerrasimos C. Yannopoulos
T. +30 210 69 67 000

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Taxand's Take

Greek enterprises should update their transfer pricing files annually, whereas comparable data selected through database searches may be used for up to three years, provided that they are refreshed annually.

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