Insights

Greece: Major Tax Litigation Win

Diana Tsourapa 02 Apr 2026

An overview by Zepos & Yannopoulos, Taxand Greece

The Tax Controversy & Litigation team at our Greek member firm, Zepos & Yannopoulos has successfully defended an applicant company’s right to tax deferral on goodwill from a business sector spin-off, achieving the cancellation of an approximate €2 million tax assessment.

The tax authority claimed the company failed to record goodwill in a separate account, making it immediately taxable. However, the Dispute Resolution Committee ruled that:

• The prior Supreme Court case law was based on an outdated accounting framework with stricter rules, no longer applicable under the current Greek Accounting Standards (Law 4308/2014), which requires a comprehensive assessment of accounting systems.
• The company had correctly recorded the goodwill in two distinct ledger accounts with clear references to Law 1297/1972 and included a relevant note in the financial statements, ensuring full transparency and traceability for the tax authorities.

The decision highlights that under Greek Accounting Standards, the substance of accurate and transparent bookkeeping should take precedence over strict formalism, if events and transactions are clearly traceable in the overall accounting records and financial statements.

The Zepos & Yannopoulos’ Tax Controversy & Litigation team was led by Diana Tsourapa, with the assistance of Alex Karopoulos, and Eva Sakellaridou. You can read the full article here.

Article tags

Case Law | Compliance | Greece | Law | Tax Disputes