The Tax on Real Property (Foros Akinitis Periousias - FAP) was imposed by Law 3842/2010 on real property in Greece that is owned by individuals or companies and applied from 2010 and forth. The relevant provisions were recently amended resulting in higher tax liability for the owners of real property in Greece.
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By a recent circular (Pol. 1155/21-7-2011) the Ministry of Finance provides guidance on the tax treatment of foreign individuals that are employed in Greece by a company established in Greece according to the provisions of Law 89/1967. The circular clarifies that such foreign employees are subject to Greek income tax only for their Greek sourced income and not for their global income.
The concept of "wholly artificial arrangements" and their use by the tax authorities as indicators of tax avoidance schemes are the subject of my article (in Greek) published in the Bulletin of Fiscal Documentation (Deltion Forologikis Nomothesias - DFN) issue Number 1470/2011.
The Ministry of Finance has issued a circular (pol. 1024/2011) providing guidance on the interpretation and application of Article 12 of the Double Tax Convention between Greece and Finland, on the tax treatment of royalties.
According to Article 13 of L. 3943/2011, the list of non-cooperative states that applies for 2011 for the purposes of Article 51A of the Greek Income Tax Code is the list included in the Ministerial Decision No. 1150236/DOS/2010 (OJ B’ 1805). Articles 51A and 51B of the Greek Income Tax Code provide for anti-tax avoidance measures.
By Circular 1141/23-6-2011 the Ministry of Finance provides guidance for the application of the new regime on the taxation of dividends distributed by Greek companies, in respect to recipients that reside in a state with which Greece has signed a Convention for the Avoidance of Double Taxation on Income and on capital. The withholdong tax rates provided in the DTCs are in general lower than the current withholding tax rate on dividend payments enacted by Law 3943/2011 (21% for distributions that take place in 2011; 25% for distributions that take place from 2012 on).
Greek tax residents that acquire interest income from bank accounts abroad, a re required to declare this income in Greece and pay a 10% final income tax. By circular 1145/5-7-2011 the Ministry of Finance clarifies that when taxpayers submit these declarations to the tax authorities, it is not required that they also submit a certified translation of the certificate issued by the foreign bank stating the amount of income derived by the Greek tax resident.
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