{"id":8102,"date":"2023-05-09T22:10:27","date_gmt":"2023-05-09T19:10:27","guid":{"rendered":"https:\/\/grandvalue.gr\/?p=8102"},"modified":"2025-04-04T14:54:46","modified_gmt":"2025-04-04T11:54:46","slug":"transfer-pricing-%ce%b5%ce%bd%ce%b4%ce%bf%ce%bf%ce%bc%ce%b9%ce%bb%ce%b9%ce%ba%ce%ad%cf%82-%cf%83%cf%85%ce%bd%ce%b1%ce%bb%ce%bb%ce%b1%ce%b3%ce%ad%cf%82","status":"publish","type":"post","link":"https:\/\/grandvalue.gr\/en\/2023\/05\/09\/transfer-pricing-%ce%b5%ce%bd%ce%b4%ce%bf%ce%bf%ce%bc%ce%b9%ce%bb%ce%b9%ce%ba%ce%ad%cf%82-%cf%83%cf%85%ce%bd%ce%b1%ce%bb%ce%bb%ce%b1%ce%b3%ce%ad%cf%82\/","title":{"rendered":"Transfer Pricing – Intra-group transactions"},"content":{"rendered":"\t\t
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The control of intra-group transactions and transfer pricing is now one of the central pillars in the search for hidden tax assets, with constant reports from the audit authorities, and is therefore a very important subject of corporate tax control.<\/p>

The term “Intra-group transactions” refers to transactions between related parties.<\/p>

Which are considered Associated Parties<\/strong><\/p>

Article 2 of Law 4172\/2013 describes the link between enterprises, between natural persons and enterprises and between natural persons.<\/p>

Natural persons are related to each other when there is a conjugal relationship or a relationship of ascendants or descendants in a direct line. That is, the androgynous couple is connected to each other, but there is also a connection to every ancestor or descendant without limit (grandfather\/grandmother\/father\/mother-son\/daughter\/grandson\/granddaughter).<\/p>

The connection between businesses as well as between individuals and businesses is divided into three main categories by law:<\/p>

  • Direct connection, where a person has a stake of at least 33% in another person then these persons are considered to be related<\/li>
  • The indirect link which can be:
    • or where a third person has a holding of at least 33% in two or more persons, those persons shall be regarded as related<\/li>
    • or where a person has an interest in another person who in turn has an interest in another person and the first person has a combined interest of at least 33% in the latter, then these persons are considered to be related (first-last)<\/li><\/ul><\/li>
    • The connection through influence which can be:
      • either direct, where one person has the ability to exercise or exerts decisive influence over another person, then those persons are regarded as related<\/li>
      • or indirect, where a third party has the ability to exercise or has the power to exercise decisive influence over two or more persons, then those persons are considered to be related<\/li><\/ul><\/li><\/ul>

        What are the obligations<\/strong><\/p>

        According to article 21 of Law 4174\/2013, there are two basic obligations for those who carry out intra-group transactions:<\/p>

        • The maintenance of an Intra-Material Transaction File<\/li>
        • The submission of the Summary Table of Intra-group Transaction Information, which is submitted electronically to TAXIS<\/li><\/ul>

          The above obligations are:<\/p>

          • Legal entities that carry out intra-group transactions of more than 100,000 euros cumulatively with all related parties, regardless of whether it is income or expense.<\/li>
          • If the turnover of legal persons is more than 5,000,000 euros then the above limit is adjusted to 200,000.<\/li><\/ul>

            Businesses are required to submit a Documentation File, which is prepared by the deadline for submitting the annual income tax return and is accompanied by a Summary Information Table, which is submitted electronically to the Tax Administration within the same deadline.<\/p>

            The deadline for companies that close their financial year on 31\/12\/2022 is 30<\/sup> June 2023, and the fines are high in cases of non-compliance.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t","protected":false},"excerpt":{"rendered":"

            The control of intra-group transactions and transfer pricing is now one of the central pillars in the search for hidden tax assets, with constant reports from the audit authorities, and is therefore a very important subject of corporate tax control. The term “Intra-group transactions” refers to transactions between related parties. Which are considered Associated Parties […]<\/p>\n","protected":false},"author":1,"featured_media":7301,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[1],"tags":[],"class_list":["post-8102","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-1"],"_links":{"self":[{"href":"https:\/\/grandvalue.gr\/en\/wp-json\/wp\/v2\/posts\/8102","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/grandvalue.gr\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/grandvalue.gr\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/grandvalue.gr\/en\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/grandvalue.gr\/en\/wp-json\/wp\/v2\/comments?post=8102"}],"version-history":[{"count":8,"href":"https:\/\/grandvalue.gr\/en\/wp-json\/wp\/v2\/posts\/8102\/revisions"}],"predecessor-version":[{"id":8110,"href":"https:\/\/grandvalue.gr\/en\/wp-json\/wp\/v2\/posts\/8102\/revisions\/8110"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/grandvalue.gr\/en\/wp-json\/wp\/v2\/media\/7301"}],"wp:attachment":[{"href":"https:\/\/grandvalue.gr\/en\/wp-json\/wp\/v2\/media?parent=8102"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/grandvalue.gr\/en\/wp-json\/wp\/v2\/categories?post=8102"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/grandvalue.gr\/en\/wp-json\/wp\/v2\/tags?post=8102"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}