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.

Related content

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


The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Request for proposal



KPMG's new digital platform

KPMG's new digital platform