By CK Accounting & Tax Services
The concept of a holding company has gained significant relevance in recent years, as more and more enterprises seek tax-efficient and organizationally flexible structures. Holding companies function as parent entities that hold equity in other businesses, primarily aiming at administrative consolidation, capital management, and more efficient tax allocation within a group.
Under Greek law, holding companies do not constitute a distinct legal form but are typically organized as Société Anonyme (S.A.) or Private Company (P.C.), with their primary purpose being the management of participations rather than commercial activity.
The operation of holding companies in Greece is governed by the general provisions of company and tax law:
- Law 4548/2018 on Sociétés Anonymes (S.A.)
- Law 4072/2012 on Private Companies (P.C.) and commercial entities
- Law 4172/2013, the Income Tax Code
Although Greece does not have a dedicated “holding regime” such as the Netherlands, Cyprus, or Luxembourg, the Greek tax system fully implements Directive 2011/96/EU (Parent–Subsidiary Directive), granting significant exemptions for intra-group transactions.
Holding companies are taxed under the general provisions of Law 4172/2013.
2.1 Corporate Income Tax
The corporate income tax rate is 22% on net profits. However, dividends received by a Greek parent company from subsidiaries within the EU are fully exempt from tax, provided the conditions of Article 48 of Law 4172/2013 are met (holding of at least 10% for a minimum of 24 months).
2.2 Dividend Distribution
When dividends are distributed to the shareholders of the holding company, a 5% withholding tax applies (Article 40 of Law 4172/2013), which may be reduced or eliminated under double taxation treaties.
2.3 Capital Gains on Share Transfers
Under Article 48A of Law 4172/2013, capital gains arising from the sale of participations are exempt from tax if the participation exceeds 10% and has been held for at least 24 months.
| Criterion | Greece | Cyprus | Netherlands |
| Legal form | S.A. or P.C. | Ltd | B.V. |
| Corporate tax rate | 22% | 12.5% | 25.8% |
| Intragroup dividend exemption | Yes (≥10%, ≥24 months) | Yes (no conditions) | Yes (≥5%) |
| Withholding tax on dividends to shareholders | 5% | 0% (non-residents) | 15% |
| Capital gains on participations | Exempt | Fully exempt | Exempt |
| Double Tax Treaties | ~57 countries | ~65 countries | ~100 countries |
| International reputation | Stable framework | Attractive regime | Strong institutional framework |
The establishment of a Greek holding company provides several advantages:
- Consolidated management and control of subsidiaries
- Intragroup financing and capital flexibility
- Asset protection and risk segregation
- Efficient tax planning
- Facilitation of ownership succession and share transfers
A holding company constitutes a modern financial and organizational instrument that can be effectively utilized by both large business groups and smaller enterprises. Despite the absence of a specific holding regime, Greek law, in combination with EU directives, creates a competitive and transparent environment for holding structures, ensuring stability, tax efficiency, and operational flexibility.
Author: Christine J. Kapela for CK Accounting & Tax Services
Accounting & Tax Consultancy | Corporate Structures and International Taxation
📧 [email protected] | 🌐 www.ck-taxservices.gr