Headquarters Establishment in Greece (Law 89/67)
Establishment in Greece of foreign commercial and industrial companies according to LAW 89/67 as amended by Law 3427/05.
Foreign1 companies may be established in Greece according to the provisions of Law 3427/05, aiming exclusively at the provision of the following services to their head-offices or affiliates abroad (within the meaning of Article 42e of Law 2190/1920):
- Consulting services
- Centralised accounting services
- Quality control of production, products, procedures and services
- Preparation of studies, designs and contracts
- Advertising and marketing services
- Data processing services
- Receipt and supply of Information and Research & Development services.
Established companies under this regime, are obliged a) to employ a staff of at least 4 employees in Greece and b) to have at least 100,000 Euro per year operating expenses in Greece.
Tax incentives for companies established under this regime:
The gross income from services provided (only collected by bank remittances) is calculated according to the cost-plus method.2 Profit margins (amounting to not less than 5%) are set separately for each company, in application of competent regulatory authority criteria (Committee of Ministry of Economy), mainly consisting in the nature of services provided, the area of business activity and the OECD Guidelines on intragroup charges.
The taxable income of the company is determined after all expenses on considered profit margin are deducted from the gross income, on the condition that they are supported by fiscal documents in compliance with the provisions of the Accounting Books and Records Code.
1. Greek companies may also be covered by the provisions of this Law upon request, where they exclusively provide the mentioned services herein at their branches abroad or at companies affiliated with them which are not established in Greece.
2. Profit margin added to total expenses and depreciations, excluding corporate income tax.