Data points
- Per-counterparty threshold where turnover is EUR 5 million or less[1]
- EUR 100,000
- Per-counterparty threshold where turnover is above EUR 5 million[1]
- EUR 200,000
- To produce the documentation file after a request[1]
- 30 days
- Shares, voting rights or profit rights that make two parties related[2]
- 33%
- Fine where the file is not produced after day 90, or never[1]
- EUR 20,000
- Ceiling on the fine for a Summary Information Table that is never filed[1]
- EUR 10,000
- Greece has adopted no legislated safe harbours or simplification measures[1]
- No safe harbours
Greece keeps its two documentation files and files a short return on top of them. That return is the piece a foreign parent misses, because it runs off the Greek corporate calendar and nothing outside Greece prompts it.
The four facts to know:
- Documentation is required once intra-group transactions with a counterparty pass EUR 100,000 a year, or EUR 200,000 where turnover is above EUR 5 million. The test runs per counterparty.
- Two files are prepared: a group file and an entity file. Both are kept, not filed, and produced within 30 days of a request.
- A separate Summary Information Table is filed electronically by the income tax return deadline, by every entity that has to keep documentation.
- A table that is never filed costs 1 in 1,000 of the transactions, with a floor of EUR 2,500 and a ceiling of EUR 10,000. A file not produced after 90 days costs EUR 20,000.
What transfer pricing documentation does Greece require?
Two files and one return. The group-level file is Greece's master file and the entity-level file is its local file, and the Greek statutory names predate the international vocabulary, so a parent searching for "master file" is looking for the Basic Documentation File. Both are prepared by the corporate income tax return deadline and kept at the taxpayer's headquarters.
The Summary Information Table is the filed piece. It is a short electronic return that summarises intra-group transactions, functions, risks and the method used, and it goes in by the same date the files have to be ready. The OECD country profile for Greece, updated in January 2026[1], sets out both duties.
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| Item | Greece's rule | Source |
|---|---|---|
| What you keep | A group file and an entity file, the master file and local file equivalents | OECD |
| What you file | The Summary Information Table, electronically | OECD |
| When | Both prepared by the income tax return deadline. Files produced within 30 days of a request | OECD |
| Threshold | Intra-group transactions above EUR 100,000 or EUR 200,000 per counterparty | OECD |
Who has to prepare transfer pricing documentation in Greece?
Any Greek entity whose intra-group transactions with a single associated counterparty cross the threshold. The limit is EUR 100,000 a year where turnover is EUR 5 million or less, and EUR 200,000 a year where turnover is above EUR 5 million. This is a transaction gate, not a group revenue gate, so a modest subsidiary with one busy intercompany relationship is caught while a larger one with many small ones may not be.
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| Entity or test | Rule | Source |
|---|---|---|
| Turnover of EUR 5 million or less | Exempt up to EUR 100,000 of intra-group transactions a year | OECD |
| Turnover above EUR 5 million | Exempt up to EUR 200,000 of intra-group transactions a year | OECD |
| Related party | 33% of shares, voting rights or profit rights, direct or indirect, or decisive influence | Independent Authority for Public Revenue, Greece |
| Outside the rules | Tax-exempt legal entities and individuals | OECD |
The 33% test sits in the income tax code published by the Greek tax authority[2]. It replaced an earlier 50% threshold, and it catches common ownership and management control alike, so a group that passed the old test can fail this one.
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Do I need a master file in Greece?
Yes, whenever the thresholds above are met. The group file and the entity file share one trigger and one set of exemptions, so there is no band where you owe one and not the other.
A group master file prepared for international purposes can serve as the content of the Greek group file, subject to the language rule below. The entity file is the work that does not travel.
What are Greece's local file requirements?
The entity file covers the taxpayer's own intercompany transactions. It is prepared by the income tax return deadline, kept at the taxpayer's headquarters, and produced to the tax authority within 30 days of a request. Its content and format are set by implementing decisions issued between 2014 and 2015.
It is not submitted routinely. Only the Summary Information Table is filed on the calendar, which is the distinction that catches parents used to regimes where the file itself goes in with the return.
What is the Summary Information Table and who files it?
A short electronic return, filed with the Independent Authority for Public Revenue[3] by the income tax return deadline. It summarises intra-group transactions, functions, risks, and the transfer pricing method used for each. Every entity required to keep documentation has to file it.
This is Greece's real distinction. Most European regimes stop at keeping documentation and producing it on request. Greece adds a filing with a hard deadline, and it is the deadline a parent abroad is most likely to miss, because nothing in the group's own calendar points at it.
Does Greece require country-by-country reporting?
Yes. Greek constituent entities of an in-scope group notify the tax authority of the reporting entity's identity by the last day of the reporting fiscal year, and the report itself is due within twelve months of fiscal year end.
The consolidated revenue threshold is the EUR 750 million international standard in practice, but the Greek tax authority leaves that field blank in the published profile, so it is Not confirmed here rather than stated as a Greek rule.
When are Greece's transfer pricing deadlines?
For a 31 December 2025 year end, the documentation file and the Summary Information Table are both due by the income tax return deadline, which has historically been the end of the sixth month after year end. The file then has to be produced within 30 days if the tax authority asks for it.
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| Obligation | Deadline for a 31 December year end | Source |
|---|---|---|
| Group file and entity file prepared | By the income tax return deadline | OECD |
| Group file and entity file produced | Within 30 days of a request | OECD |
| Summary Information Table | Electronically, by the income tax return deadline | OECD |
| Country-by-country notification | By the last day of the fiscal year | OECD |
| Country-by-country report | Within twelve months after fiscal year end | OECD |
Confirm the exact 2026 return date for the 2025 year before you rely on it. Greek corporate return dates have moved in recent years.
What language does the documentation have to be in?
Greek, with one exception. A foreign group's master file may be kept in an internationally accepted language, preferably English, and a Greek translation is then due within 30 days of a request. Everything else is kept in Greek, and the Summary Information Table is filed through the Greek electronic system.
A parent that assumes English is fine throughout risks a translation demand inside a 30-day window it is already using to assemble the file.
What are the penalties for getting Greece transfer pricing wrong?
Two separate schedules. The Summary Information Table has its own fines, charged as a fraction of the transactions with a floor and a ceiling. The documentation file has an escalating fine that depends on how late you produce it, and both double on a repeat failure within five years. Inaccuracy penalties on the table apply only above a 10% discrepancy.
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| Failure | Penalty | Source |
|---|---|---|
| Summary Information Table late, inaccurate or incomplete | 1 in 1,000 of the transactions, minimum EUR 500, maximum EUR 2,000 | OECD |
| Summary Information Table not filed | 1 in 1,000 of the transactions, minimum EUR 2,500, maximum EUR 10,000 | OECD |
| File not produced, days 31 to 60 | EUR 5,000 | OECD |
| File not produced, days 61 to 90 | EUR 10,000 | OECD |
| File not produced after day 90, or never | EUR 20,000 | OECD |
| Repeat within five years, then a further repeat | Doubled, then quadrupled | OECD |
| Country-by-country report not filed, or late or inaccurate | EUR 20,000, or EUR 10,000 | OECD |
What is a foreign parent exposed to in Greece?
The Greek subsidiary carries the filing obligation, but missing documentation exposes the whole group. The risks are arm's length adjustments, the escalating production fines above, and the audit friction that follows a file that arrived late.
A late Summary Information Table triggers automatically off the Greek return calendar, which is easy to overlook from abroad. The parent should track that date centrally rather than leave it to local staff who may assume headquarters is handling it.
How does Greece differ from the OECD baseline?
Greece follows the OECD Transfer Pricing Guidelines, with four differences that change how you prepare. It files a Summary Information Table where most countries only keep documentation. It uses transaction-value thresholds rather than a single group revenue gate. It keeps its own two-file naming. And it has adopted no safe harbours at all.
Greece has also not adopted the simplified approach to low value-adding intra-group services, so routine management charges get the full treatment. The Amount B baseline distribution approach is still under consideration. Advance pricing agreements are available in unilateral, bilateral and multilateral form.
How we help with Greek transfer pricing
Greece runs a filing and a file on the same date, and checks one against the other when it asks. We prepare the group file and the entity file, build the benchmarking behind the Greek entity's margins, and file the Summary Information Table by the return deadline so the two agree. See how our transfer pricing software works.
Book a demo to check your Greek documentation and Summary Information Table exposure before the next return deadline.
Official sources
3 sources
- 1.OECD. Transfer pricing country profile: Greece (January 2026)
- 2.Independent Authority for Public Revenue, Greece. Income Tax Code, Law 4172/2013 (associated persons)
- 3.Independent Authority for Public Revenue, Greece. Independent Authority for Public Revenue, taxpayer portal
Article by
Logan Jackonis
Head of Services & Operations, Commenda
Logan leads Commenda’s Services and Operations team, helping controllers, heads of tax, and finance leaders navigate international expansion. He built a global expert network across 70 countries and previously worked in management consulting across the Middle East and Southeast Asia.
Disclaimer: Commenda and its affiliates do not provide tax, accounting, or legal advice. This material has been prepared for informational purposes only, and is not intended to provide or be relied on for tax, accounting, or legal advice. You should consult your own tax, accounting, and legal advisors before engaging in any related activities or transactions.
