The new era for businesses, the decline of traditional offshore models, and the rise of Greek holding companies.
Introduction – The end of offshore companies without real substance
For many years, Greek entrepreneurs relied on companies established in Cyprus, Bulgaria, Romania, and various offshore jurisdictions — mainly for tax-driven reasons.
However, the landscape has changed dramatically.
With the implementation of ATAD, the global BEPS framework, CRS automatic exchange of information, and strict substance requirements, foreign companies without real presence are now considered high-risk structures.
Greece, on the other hand, now offers a modern, safe, and tax-competitive environment for establishing holding companies — with advantages that did not previously exist.
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2.1 Lack of real substance = tax risk
Under Article 38 of the Greek Tax Procedure Code, the Tax Administration may disregard a corporate structure if it lacks real commercial activity, physical presence, staff, and decision-making abroad.
Audits now focus on:
• Where management decisions are made
• Whether local employees exist
• Whether the company has a physical office
• Whether the company conducts actual commercial transactions in its country of incorporation
2.2 Controlled Foreign Company rules (CFC)
According to Article 66 of the Income Tax Code, the profits of a foreign company without substance may be attributed and taxed directly to the Greek shareholder.
2.3 Banking risk & KYC/AML restrictions
European banks now:
• Refuse to open accounts for companies without substance
• Require full documentation to prove economic presence
• Close offshore accounts that lack real activity
2.4 CRS – Full transparency
All foreign banks automatically report the financial information of Greek tax residents to the Greek Tax Authority (AADE).
There is no longer any “opacity” or data protection through offshore structures.
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Two key decisions — DED Athens 1413/2023 and DED Thessaloniki 1033/2019 — clarified that:
Foreign companies without staff, offices, real management, or commercial substance are considered artificial arrangements and must be taxed in Greece.
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With Laws 5162/2024 and 4601/2019, Greece now enables:
• Cross-border mergers
• Cross-border absorptions
• Transfers of registered seat between countries
• All with full tax neutrality
This means a Cypriot, Bulgarian, or any other foreign company can be transferred to Greece without capital gains tax, without transfer tax, and without special levies.
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✔️ Participation exemption (Article 48 ITC)
• 0% tax on dividends
• 0% tax on capital gains from the sale of shares
✔️ Compliance with EU and international standards
Ideal for:
• Family offices
• Corporate groups
• Investors
• Startups with foreign SPVs
• Export-oriented companies
✔️ Legal and banking credibility
• High acceptance by EU banks
• Easier access to financing
• Strong trust in due diligence and audits
✔️ Real substance in Greece
With significantly lower operating costs compared to other EU jurisdictions.
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It is the optimal structure when:
• There are shareholdings in other companies
• There is business activity in Greece
• A transparent and compliant corporate structure is required
• There is a plan to repatriate foreign entities safely
• There are investment plans or international partnerships
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The era of offshore structures without real economic presence is over.
Today’s global environment demands transparency, substance, and full compliance.
For the first time in decades, Greece offers:
tax competitiveness + legal certainty + international credibility.
Greek holding companies are now the safest, most efficient, and most future-proof corporate solution for modern entrepreneurs.
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At CK Accounting & Tax Services, we provide:
• Establishment of Greek holding companies
• Full relocation of foreign entities to Greece with tax neutrality
• Group structuring & corporate planning
• Due diligence & substance planning
• Ongoing accounting and tax compliance
📩 Contact us today to review your corporate structure and design a safe, compliant transformation plan.