Related-party terms should reflect independent-party conditions.
Article 50 of the Greek Income Tax Code applies the arm's-length principle to domestic and international related-party transactions.
The Tax Procedure Code imposes documentation requirements.
Article 25 covers related parties and specified permanent-establishment dealings.
EUR 100,000 or EUR 200,000 depending on turnover.
The exemption applies where covered transactions are up to EUR 100,000 in aggregate when annual turnover does not exceed EUR 5 million, or up to EUR 200,000 where turnover exceeds EUR 5 million.
Being below the filing threshold does not eliminate the underlying arm's-length principle.
The file and Summary Information Table follow the annual income-tax return deadline.
The current Tax Procedure Code sets the documentation-file preparation deadline and Summary Table submission by the annual income-tax return deadline.
The file must be available on request.
It must be provided to the tax administration within 30 days of the relevant request.
Functions, assets and risks come before pricing.
A markup without understanding economic functions is not a transfer-pricing policy.
Contracts should match operational reality.
Services, licences, financing, goods and cost allocations need a consistent contractual and accounting trail.
Operational TP readiness before annual documentation.
International & Cross-Border Advisory maps intercompany flows, agreements, invoicing and ledger data so annual documentation rests on controlled information.