My Publications
2022
Chapter 11 – International Tax Law and Public International Law, co-authored with Ch. HJI-Panayi, in: F. Haase and G. Kofler (eds), The Oxford Handbook of International Tax Law, OUP, forthcoming (expected December 2022)
Th. Fortsakis - A. Tsourouflis Tax Law (Φορολογικό Δίκαιο) (in Greek), 7th ed., collaborator, Nomiki Vivliothiki 2022
2021
Case Law Note: The Application of the EU Charter of Fundamental Rights to Tax Procedures: Trends in the Case-Law of the Court of Justice, Intertax vol. 49, Issue 10 (2021), pp. 853-861
Chapter 3 - Taxpayers’ rights in trans-border dispute on tax matters, in: E.A. Aucejo & A.O.Rayo (eds), Global Tax Governance, Taxation on Digital Economy, Transfer Pricing and Litigation in Tax Matters (MAPs+ADR). Tax Policies for Global Sustainability. Ongoing U.N. 2030 (SDG) and Addis Ababa Agendas, Thomson Reuters 2021, pp. 323-332.
Chapter 21 – Greece, in: W. Haslehner & M. Lamensch (eds), Taxation and Value Creation, EATLP International Tax Series, Vol. 19, IBFD 2021, pp. 413-426.
Greece – Rollback of APAs in Greece, International Transfer Pricing Journal, 2021 (Volume 28), No. 3 (Next issue), published online: 24 March 2021
Greece – Making the Mutual Agreement Procedure more effective in Greece: a Commentary on the Guidelines for the conduct of MAPs, European Taxation 2021 (Volume 61), No. 2/3, published online 12 January 2021
Chapter 3: The Use of a Third Person other than a Court in Order to Deal with Tax Disputes: The Greek Experience, in: P. Pistone and J. DeGoede, Flexible Multi-tier Dispute Resolution in International Tax Disputes, IBFD 2021, pp. 43 et seq.
Chapter 11: Using Mediation for the resolution of cross-border tax disputes, in: P. Pistone and J. De Goede, Flexible Multi-tier Dispute Resolution in International Tax Disputes, IBFD 2021, pp. 197 et seq.
2020
Greece – Tax loss utilization through company reorganizations, European Taxation 2020 (vol. 60) no. 2/3
Chapter 24 – Fundamental rights in EU tax law, in HJI Panayi, Haslehner and Traversa (eds) Research Handbook on European Union Taxation Law, Elgar 2020, pp. 511 et seq.
Chapter 25 – Dispute resolution and taxpayer participation, in HJI Panayi, Haslehner and Traversa (eds) Research Handbook on European Union Taxation Law, Elgar 2020, pp. 541 et seq.
2019
Chapter 1: Greece: Scope of Application of the Treaty in Case of Income from Unknown Sources, in: E.C.C.M. Kemmeren et.al. (eds), Tax Treaty Case Law around the Globe 2018, IBFD/Linde 2019, pp. 3 et seq.
Chapter 11: Greece: Attribution of Profits to PE and Limitations of Deductible Expenses
under Domestic Law, in: E.C.C.M. Kemmeren et.al. (eds), Tax Treaty Case Law around the Globe 2018, IBFD/Linde 2019, pp. 113 et seq.
under Domestic Law, in: E.C.C.M. Kemmeren et.al. (eds), Tax Treaty Case Law around the Globe 2018, IBFD/Linde 2019, pp. 113 et seq.
Taxpayer Rights and Taxpayer Participation in Procedures Under the Dispute Resolution Directive, Intertax, Volume 47 (2019) Issue 8/9, pp. 715–724 (double blind peer-reeviewed)
Towards a Standing Committee Pursuant to Article 10 of the EU Tax Dispute Resolution Directive: A Proposal for Implementation, Sophia Piotrowski, Roland Ismer, Philip Baker, Jérôme Monsenego, Katerina Perrou, Raffaele Petruzzi, Ekkehart Reimer, Fernando Serrano Antón, Lukasz Stankiewicz, Edoardo Traversa, Jasna Voje, Intertax, Volume 47 (2019) Issue 8/9, pp. 678–692 (double blind peer-reviewed)
2018
“The Ombudsman and the Process of Resolution of International Tax Disputes – Protecting the “Invisible Party” to the MAP, World Tax Journal 2018 (volume 10), no. 1 (double blind peer-reviewed)
Chapter 18: Greece in Improving Tax Compliance in a Globalized World (C. Evans et al. eds., IBFD 2018), Online Books IBFD.
Chapter 10: Interest and penalties in Tax Procedures Code, Systematic per Article Interpretation of Law 4174/2013, (J.G.Photopoulos ed., Sakkoulas 2018) (in Greek), pp. 1413-1539, pp. 1579-1600, and pp. 1631-1746
2017
“Making Transfer Pricing Adjustments Effective: Are the Tax Authorities Obliged to Reopen Fiscal Years for Which Corrective Tax Assessments Have Been Issued, after a Full Tax Audit?,” 24 Intl. Transfer Pricing J. 2 (2017), Journals IBFD, pp. 147 et seq.
“Foreign Corporate Income Tax Credit – A Case of Treaty Override Caused by Domestic Case Law,” 57 Eur. Taxn. 2/3 (2017), Journals IBFD, pp. 105 et seq.
“Commission v Greece: Greek preferential inheritance tax for bequests of which the beneficiaries are non-profit-making legal persons.” Comment on the case law, Highlights and Insights on European Taxation, Volume 9, p. 290, Wolters Kluwer 2017 [ISSN: 1876-665X]
2016
“New Law Amends Transfer Pricing Documentation Rules and APA Procedure,” 23 Intl. Transfer Pricing J. 6 (2016), Journals IBFD,pp. 517 et seq.
“Tax Law Disputes before Investment Arbitration Panels: Practical Experience” 56 Eur. Taxn. 10 (2016), Journals IBFD, pp. 451 et seq.
“Greece – Clarifications on transfer pricing published”, Intl Transfer Pricing J, vol. 23, 2, pp. 161 et seq.
“Dispute resolution procedures in international tax matters”, Greece, Branch Report in: IFA, Cahiers de droit Fiscal International, volume 101 (2016 Madrid Congress)
2015
“Participation of the taxpayer in MAP and arbitration: Handicaps and Prospects”, Chapter 11 in: M. Lang - J. Owens (eds), International Arbitration in Tax Matters, IBFD, December 2015
“The practical protection of taxpayers’ fundamental rights”, Greece, Branch Report in: IFA, Cahiers de droit Fiscal International, volume 100B, 2015 Basel Congress
“Greece: New CFC rules”, European Taxation, vol. 55, 4, pp. 173 et seq.
“Greece: Legislation requires withholding tax to be paid on certain payments to branches established in Greece but not payments between Greek payments”, European Taxation, vol. 55, 1, pp. 33 et seq.
“Greece: APA guidance released by tax authorities”, Intl Transfer Pricing J, vol. 22, 2, pp. 116 et seq.
2014
“Taxpayer participation in DTC dispute resolution”, IBFD Doctoral Series, volume 28 (Book; PhD thesis)
“Greece: Decision of the Secretary General for Public Revenue on transfer pricing documentation rules”, ITPJ 2014, vol. 21, 6, pp. 457 et seq.
“Greece: taxes covered – is an extraordinary levy on business profits covered?”, in: M. Lang e.a. (eds), Tax Treaty Case Law around the Globe 2013, IBFD/Linde 2014, pp. 13 et seq
2013
“Greece – APA introduction and transfer pricing legislation”, ITPJ 3013, vol. 20, 4, pp. 273 et seq
“Greece: Construction permanent establishment”, Chapter 7 in: E.C.C.M. Kemmere e.a. (eds), Tax Treaty Case Law around the Globe 2012, IBFD/Linde 2013, pp. 63 et seq.
“The concept of tax residence” (Η έννοια της φορολογικής κατοικίας), Tax law Bulletin (ΔΦΝ) 2013, pp. 323 et seq. (in Greek)
2012
"Tax treatment of acquisition of shares in a capital company established in another MS or in a third state: freedom of establishment or free movement of capital?" (in Greek), Deltion Forologikis Nomothesias (DFN) 2012, pp. 1236-1241.
"Greece - Corporate Loss Utilization through Aggressive Tax Planning", ITPJ, May/June 2012, pp. 205-211.
"The reimbursement of indirect taxes unduly paid" (in Greek), Deltion Forologikis Nomothesias (DFN) 2012, pp.403-406.
2011
"The distortion of competition through discriminatory tax treatment and its consequences. How a cheap entrance ticket to the Casino can be very expensive" (in Greek), Business and Company Law Review 2011, 1129-1136.
"Greece: The Calculation of the Profits that are Attributable to a PE" in M. Lang et al (eds), Tax Treaty Case Law around the Globe - 2011, Linde Verlag, Vienna 2011, 177-183.
"Wholly artificial arrangements" and presumptions of tax avoidance, EC Tax Journal 2011, 11(2), 57-76.
"Wholly artificial arrangements" and presumpions of tax avoidance, Deltio Forologikis Nomothesias (DFN) 2011, pp. 1030 et seq. (in Greek)
Court of Justice, C-155/09, Commission v. Greece. Prohibited discrimination. Exemption from transfer tax on first purchase of immovable property (comments by Perrou), H&I 2011/05.3
Comment on C-155/09.H&I 2011/05.3
Comment on C-155/09.H&I 2011/05.3
2010
Greece: Commission v. Hellenic Republic (C-155/09), in: M. Lang et al (eds.), ECJ - Recent developments in Direct Taxation 2009 (Linde Verlag), 2010 (with Prof. Theodore Fortsakis)
2009
Time limits, legal protection and their extension, Chapter 26 in: P. Pistone (ed.), Legal Remedies in European Tax Law (IBFD), 2009
2008
Greece: The Commission v. Greece case, in M. Lang et al (eds.), ECJ - recent developments in direct taxation 2008 (Linde Verlag, 2008 (with Prof. Theodore Fortsakis)
Contributor, "Chapter 6on the Procedural aspects of tax law" in the handbook: "Tax Law" by Prof. Theodore Fortsakis, 2nd Edition 2003; 3d Edition 2008, Sakkoulas, Athens-Komotini (in Greek).
EU - Tax: National Report Greece, in M. Lang et al (eds.), EU Tax (Linde Verlag), 2008 (with Dr.
Georgios Matsos)
Georgios Matsos)
Commission requests Greece to amend its discriminatory tax provisions applicable to the acquisition of a first residential real estate in Greece. European Commission (comments by Perrou), H&I 2008/02.16
2007
The EU and third countries: direct taxation: National Report Greece, in: M. Lang & P. Pistone (eds.), The EU and third countries: direct taxation (Linde Verlag), 2007, (with Dr. Georgios Matsos)
Parliament Adopts Individual Income Tax Changes, Tax Notes Int'l, February 26, 2007, p. 739
The fiscal liability of directors of legal entities for the fiscal debts of the legal entity - especially the case of measures for the protection of the State's interests, Deltio Forologikis Nomothesias (DFN) 2007, pp. 1702 et seq. (in Greek)
2006
Double taxation conventions and social security conventions: National report Greece, in: M. Lang (ed.), Double taxation conventions and social security conventions (Linde Verlag), 2006
The attribution of profits to Permanent Establishments, Greek National Report, in: IFA, Cahiers de droit Fiscal International, Amsterdam Congress 2006, 2006
The judicial application of anti-avoidance doctrine in Greece and its impact on international tax law, Intertax, February 2006
Article 39 of the Greek Income Tax Code-Transfer Pricing Rules-The concept of associated enterprises; comment on the decision of the Greek Supreme Administrative Court 1644/2005, published in BUSINESS 2006, pp. 96 et seq. (in Greek)
Double Taxation Conventions and Cost Sharing Agreements; comment on the decision of the Administrative Court of Athens 146/2004, published in BUSINESS 2006, pp. 215 et seq. (in Greek)
2005
Observations on the Opinion No. 326/2004 of the Legal Council of the State (on fiscal secrecy), Private Law Chronicles E/2005, pp. 77 et seq. (in Greek)
Opinion 326/2004, Legal Council of State (in Greek)
Opinion 326/2004, Legal Council of State (in Greek)
Article 30 of the Greek Code of Fiscal Books and Records – Disregarding the content of the Books; comment on the decision of the Administrative Court of First Instance of Athens 1631/2004, published in BUSINESS 2005, pp. 915 et seq. (in Greek)
Partnerships: representation in case of dissolution; statute of limitation of tax liability; comment on the decision of the Administrative Court of First Instance of Athens 4111/2003, published in BUSINESS 2005, pp. 342 et seq. (in Greek)
The conditions for the temporary VAT tax determination; comment on the decision of the Administrative Court of Appeals of Thessaloniki 2120/2004, published in BUSINESS 2005, pp. 341 et seq. (in Greek)
Sanctions for ensuring the collection of taxes; comment on the decision of the Administrative Court of First Instance of Athens 15536/2004, published in BUSINESS 2005, pp. 141 et seq. (in Greek)
Sanctions for ensuring the collection of taxes; comment on the decision of the Court of First Instance of Athens 786/2004, published in BUSINESS 2005, pp. 137 et seq. (in Greek)
2004
Cross border investment in real estate and its financing - Tax Aspects; AΙJA Conference Naples 24-28 August 2004; National Report of Greece (finalized on 10 February 2004)
Cross border loss relief for associated enterprises - a problem from the future seeks (positive or negative) harmonization, Business and Company Law 11/2004, pp. 1139 et seq. (in Greek)
Tax Legislation, member of the group of editors of the book "Tax Legislation", General Editors Th. Fortsakis - J. Photopoulos, Nomiki Bibliothiki Publications, Athens 2004 (1st Edition); 2006 (2nd Edition) (in Greek)
2003
The special tax on real property, Private Law Chronicles Γ/2003, pp. 844 et seq. (in Greek).
2002
Settlement of Disputes in Greek Tax Treaty Law, in: M. Lang & M. Zueger (eds.), Settlement of disputes in Tax Treaty Law (Kluwer), 2002
Arbitration for international tax disputes, Private Law Chronicles B/2002, pp. 363 et seq. (in Greek)
Tax sanctions in the USA law, in: J. Photopoulos (ed.), Tax sanctions, Sakkoulas Publications, Athens, 2002 (in Greek)
The Mutual Agreement Procedure in the Double Taxation Conventions, Deltio Forologikis Nomothesias (DFN) 2002, pp. 581 et seq. (in Greek)
2001
Tax Treaty Interpretation in Greece, in: M. Lang (ed.), Tax Treaty Interpretation (Kluwer Law International), 2001
The concept of royalties in the OECD Model Tax Convention on Income and Capital, Private Law Chronicles A/2001, pp. 470 et seq. (in Greek)
