The domestic rule starts with a fixed place of business.
Greek income-tax law defines a PE as a fixed place through which the business is carried on wholly or partly.
Management location, branch, office, factory or workshop.
A separate Greek legal entity is not required before PE questions can arise.
Construction and assembly have a specific domestic time test.
The applicable tax treaty must also be checked because treaty thresholds may differ from domestic law.
Contract authority can matter.
A person acting for the enterprise and habitually exercising authority to conclude agreements in its name can trigger the domestic agent rule, subject to exceptions.
Genuinely independent agents are treated differently.
Ordinary independent-agent activity does not automatically create a PE.
Specific preparatory or auxiliary activities may be excluded.
Storage, display, purchasing and information-gathering can fall within exceptions when statutory conditions are met.
Ownership alone does not create a parent's PE.
The relationship and actual operating facts still need review.
Always check the applicable DTA.
Where Greece has a double-tax treaty with the residence state, the treaty text must be included in the analysis.
PE leads to profit attribution and compliance questions.
Accounting, tax filings, head-office dealings and transfer pricing may follow.
Review people, contracts, premises and transaction flows.
International & Cross-Border Advisory maps actual activity rather than relying on the organisation chart alone.