-          Foreign companies may be established in Greece pursuant to the provisions of this law in order to provide exclusively consulting services, centralization of accounting services, quality control of production, products, procedures and services, preparation of studies, designs and contracts, advertising and marketing services, data processing, receipt and supply of information and research and development services, to their associated enterprises that are not established in Greece, and / or to their head office.

-          The enterprises established are obliged a) to employ at least 4 employees at the end of the twelve – month period following the date the decision mentioned in the next paragraph is issued and b) that their annual operating expenses incurred in Greece will not be less than € 100.000 (one hundred thousand Euros).

-          A special license is required for the application of this law, which is granted by a decision of the Minister of Economy and Finance, published in the Government Gazette. The license is issued within fifty (50) days the latest from the filing of a relevant application to the Directorate of Foreign investments in the Ministry of Economy and Finance.

-          The gross income of the companies deriving from the services they provide and which is compulsory collected through bank remittances, is reached with the application of a profit percentage on their total expenses and depreciations, excluding corporate income tax (cost plus method).  The said profit percentage is reviewed every five years or even earlier if the market conditions alter significantly.

-          For the determination of the profit percentages, which cannot be less than 5% are taken into consideration, mainly, the nature of the services provided, the field of activities and the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.

-          For the determination of the mark up, all expenses on which the profit percentage applies shall be tax deductible for corporate income tax purposes, on the condition that they are supported by fiscal documents in compliance with the provisions of the Code of Books and Records.

Greece has signed more than fifty (50) tax treaties since 1953. These treaties define certain key terms, such as the place of tax action or “permanent establishment” and also provide tax exemptions at source or special treatments for certain types of income. All tax treaties (except those with USA and UK) follow in principle the OECD model.