Guidelines for APAs in Greece | KPMG | BE

Greece: APA procedures, process

APA procedures, process in Greece

Guidelines issued by Greece’s Ministry of Finance set forth the procedures for advance pricing agreements (APAs), and within this framework, templates of the APA application form have been provided, and the process concerning the preliminary consultation has been outlined.


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Under this process:

  • An APA can be unilateral, bilateral or multilateral.
  • An APA is used to establish a transfer pricing method in accordance with the “arm’s length principle” for a given time period.
  • Additional criteria—e.g., the comparable data to be used—for the determination of the intercompany prices may be agreed.
  • Supporting documentation and information to be submitted with the application for a preliminary consultation and with the APA application itself is specifically set forth.
  • Within the framework of the APA procedure, tax authority officials may visit the taxpayer’s premises (with consent) to ascertain the conditions of the business operations.
  • The length of time allotted for the evaluation state and issuance of the APA cannot exceed 120 days from the date when the APA application is submitted (provided a foreign tax authority is not involved).
  • The APA is effective from the date that it has been agreed to by the interested parties.
  • The APA cannot concern a tax year prior to the submission of the APA application, and the APA’s duration cannot exceed four years.
  • Following the issuance of the APA, the taxpayer must prepare and submit an annual compliance report to demonstrate compliance with the provisions of the APA.
  • The taxpayer’s transfer pricing documentation obligation covers all intercompany transactions (not only cross-border), while the APA procedure relates only to future cross-border intercompany transactions. 


Read a 2014 report prepared by the KPMG member firm in Greece: Guidelines issued by the Ministry of Finance regarding the procedure for the issuance of Advance Pricing Agreements


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