Well-regarded compact firm that is best known for its strong tax practice. Particularly respected for its strong tax litigation offering that includes representing clients before Greek courts and the ECJ. Also advices on tax planning and restructuring. Represents an impressive roster of clients comprising both international and Greek corporates.
CHAMBERS AND PARTNERS EUROPE 2017
Our law office successfully participated on behalf of a corporate client in a pilot trial before the Supreme Administrative Court in favor of the validity of the “clean” tax audit certificate issued by certified auditors. The decision of the Supreme Administrative Court clarified critical legal issues endorsing inter alia our legal argumentation that the tax authorities cannot conduct regular tax audit in cases considered as “closed” as long as a tax audit certificate without findings is in place for years 2011-2013
Our tax litigation team provided advisory services and represented two clients in the beverage sector before the Dispute Resolution Directorate in administrative dispute resolution related to cross-border transfer pricing disputes of high legal complexity – pending
We have initiated administrative resolution proceedings for a client in the beverage sector in a case dealing with the issue of transfer of tax losses further to cross-border transfer pricing adjustments – pending
We have successfully represented a multinational company operating in the food and beverage industry before the Supreme Administrative Court in a series of court cases dealing with the payment of interest on unduly paid tax and ensured the payment of more than EUR 5 million
We have initiated tax litigation proceedings for a foreign corporate client (online games and gambling operator) against income and special GGR tax assessment acts and have successfully accomplished the suspension of payment of the record-high amount of EUR 23,8 million
Our tax litigation team successfully represented a client in the construction sector in a tax litigation against income tax, VAT and Code of Books and Records audit assessments, by invoking legal argumentation related to the statute of limitations of the Greek State’s right to assess tax on the basis of information that was already available to the tax authorities at the time of closure of tax cases (peraiosi)
Our tax litigation team successfully represented a leading pharmaceutical company before the Athens Administrative Court of Appeal and achieved an unprecedented win in a tens of million-income tax and transfer pricing challenge. The Court upheld our arguments on the tax productivity of various types of expenses, including expenses for medical events, while it annulled in total the transfer pricing adjustment and the corresponding transfer pricing fine and ordered refund of the unduly paid tax with interest
We have initiated tax litigation proceedings before the Administrative Court of Appeal representing two leading pharmaceutical companies against multimillion income tax assessments – pending
Our tax team successfully represented before the Administrative Courts, in a number of court cases, a Greek company (waste management industry) in claiming refund of unduly paid income tax and interest of nearly EUR 1 million. The Court upheld our argumentation and expressly recognized the application of general income tax provisions related to tax losses notwithstanding existence of a special untaxed reserve intended to set-off accounting losses
Our tax team successfully represented a multinational company (food and beverage sector) in securing before the Supreme Administrative Court final annulment of a EUR 4,2 million state-aid recovery assessment plus interest
Our tax team challenged before the Dispute Resolution Directorate and the Athens Administrative Court of Appeal a tax assessment, amounting to EUR 1,5 million of tax, issued against a taxpayer for deemed income based on bank transfers and deposits. We succeeded in the annulment of the tax assessment by pleading erroneous application of the law and jurisprudence from the tax authorities
Our tax team successfully advised and represented before the Greek Tax Authorities a leading company in the tobacco industry in a process for reduction of advance CIT calculated originally on excessive CIT of previous year due to nonrecurring income. Further to our representations and argumentation the Tax Authorities accepted our claim to reduce dramatically the advance CIT by approximately EUR 60 million in a well-timed fashion
The tax team successfully represented a high-profile international oil and gas operations company before the Athens Administrative Court of Appeal in a multimillion tax dispute related to imposition of excessive fines following a transfer pricing adjustment. The Court endorsed our argumentation related to enforcement of the more favorable penalty principle and dramatically eliminated the fines
We successfully represented a multinational company (food and beverage industry) before the European Court of Justice and the Greek Administrative Courts and achieved refund plus interest of dividend income tax as contrary to the Parent/Subsidiary Directive
We successfully represented a major Greek company (oil industry) in administrative courts for annulment of tax assessment acts involving record-high amounts
We represented two leading Greek companies (food and beverage industry) in tax court proceedings against multi-million tax assessments in respect of direct taxation and transfer pricing issues – pending
We obtained a favorable decision at administrative level on refund to a multinational (food and beverage industry) of withholding tax on management fees paid to EU-based affiliates in violation of respective double taxation treaty provisions
We initiated MAP proceedings under the Arbitration Convention in respect of a multi-million transfer pricing case involving an EU company and its Greek subsidiary (fashion industry)
Our firm successfully represented, in a number of tax court cases, a foreign tax resident and Chairman of the Board of Directors of the Greek subsidiary of a multinational company in claiming refund of unduly paid tax on deemed income imputed in connection to company cars as contrary to the provisions of the applicable double taxation treaty
We successfully handled at administrative level a tax refund claim on employment income acquired by a foreign tax resident assigned to a foreign subsidiary by the Greek subsidiary of a multinational Group
We successfully represented a major Greek multinational company (oil industry) in administrative courts for annulment of tax assessment acts issued despite a “clean” tax certificate
We provided our legal opinion in respect to restructuring of non-performing syndicated loans and sale and lease back agreements
We successfully represented two clients (food and beverage industry/fashion industry) before the administrative courts in claiming refund of withholding tax on management fees paid to EU-based mother companies by pleading violation of respective double taxation treaty provisions
We assisted and represented high-net-worth individuals in respect to multi-million income tax audits and cases achieving dramatic reductions in the amounts of taxes originally assessed
We advised individuals-foreign tax residents as well as multinational employers in relation to tax aspects of exercise of stock options associated to employment in Greece
We regularly provide advice, prepare relevant queries and support the issue of interpretative tax rulings by the Tax Administration
We review and provide tax advice in relation to various types of agreements (trademark license, I/C loan agreements, commercial agreements etc.)
We regularly provide tax advice on transfer pricing issues related to planning, compliance, documentation and dispute resolution
We assisted a major JV (construction industry) and represented it before the tax authorities in reaching a very favorable settlement of open court cases
We obtained a dramatic reduction (by 95%) of income tax imposed to a foreign company on deemed income related to real estate in Greece
Our law office paved the way for the much anticipated decision of the Greek Supreme Administrative Court by representing a leading multinational company in this pilot case procedure and by securing recovery of VAT of a substantial amount related to the part of the total claim which was written off in the framework of a restructuring agreement of a customer
Further to this development, our tax team successfully represented a big number of corporate clients in the beverage sector before the Administrative Courts, at administrative tax dispute resolution level and in out-of-court procedures in related cases
We represented a multinational company operating in the food and beverage industry in tax litigation related to its claims for refund of municipality tax paid in violation of the EU legislation and ensured a 100% refund plus legal interest
We have initiated litigation proceedings for several clients operating in the pharmaceutical sector claiming refund of VAT on rebates granted to social security organizations and hospitals – pending
We participated in a series of tax litigation cases representing a client operating in the car industry before the Administrative Courts in VAT cases dealing with complex legal issues on the application of the EU VAT Directive – pending
We successfully represented two multinationals (food and beverage industry) before the administrative courts challenging the non-deduction of input VAT as being in violation of the EU VAT Directive and ensuring multi-million refunds plus interest to both companies
We achieved favorable outcome on significant tax court cases in respect of VAT refund claims arising from input VAT on capital goods (HORECA sector)
Our office handled successfully in administrative courts a case against VAT assessments made by the customs authorities related to provision of quantitative discounts to customers
We advise and assist on a regular basis our clients engaged in alcohol, tobacco and coffee industries operating a licensed warehouse in respect to a wide range of issues related to excise tax and customs regulations
We have initiated court proceedings on behalf of a multinational (food and beverage industry) claiming refund of excess paid excise duty in flavored beverage due to violation of domestic and EU legislation