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ARTICLE · 03 NOVEMBER 2026

September 2026 Monthly Tax Briefing

Bernitsas
Bernitsas
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Bernitsas

Bernitsas

Bernitsas is a market leader in the provision of commercial law services in Greece and one of the...

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Until the issuance of Decision 1734/2025, the Council of State had not ruled on whether a domestic company may deduct royalty withholding taxes from its gross revenue when the parties have contractually agreed to a tax-free payment.

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Recent Developments in Tax Legislation

A. Council of State Decision 1734/2025 - Deduction of Excess Royalty Payments Made Under a Gross-Up Clause
B. Council of State Decision 370/2026 - Intragroup Loan for Dividend Payments to Shareholders - Interest Deduction
C. Council of State – Decision 364/2026 - The 10-year Statute of Limitations Applicability to Fictitious Invoices
D. Decision A.1192/2026 – Inclusion in the Provisions of Article 5B of Law 4172/2013 on Pensioners Relocating Permanently to Greece

A. Council of State Decision 1734/2025 - Deduction of Excess Royalty Payments Made Under a Gross-Up Clause

Until the issuance of Decision 1734/2025, the Council of State had not ruled on whether a domestic company may deduct royalty withholding taxes from its gross revenue when the parties have contractually agreed to a tax-free payment.

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