Despina Doxaki

An interesting recapitulation on Greece’s latest taxation issues on Vessels and Shipping Companies comes from the KYRIAKIDES GEORGOPOULOS Law Firm, worth having in mind.

Taxation of Vessels – Shipping Companies

(a)       What Changes? Taxation

1. Ships Under Foreign Flag – Management from Greece,

Taxation of ships under foreign flag, in case their management is exercised by Greek companies or foreign companies established in Greece.  Amendment of article 26 of La. 27/1975.

1. Subjects to tax:

The foreign ship-owners or ship-owner companies. The managing companies, which are established in Greece under the provisions of art. 25 of law 27/1975 are jointly liable for the remittance of the tax.

1. Calculation of the tax – Tax Credit:

–           With the same criteria as the tax imposed on ships under Greek flag (tonnage tax).

–           Any tonnage or similar tax proved to be remitted for the ship under foreign flag abroad is deducted from the Greek tax, up to the amount due in Greece.

1. Taxation of Dividends and Distributable Profits

Exemptionof the shareholdersof the above mentioned companies from any tax, duty, contribution or withholding, up to natural person, for the income acquired from dividends or distribution of net profits, whether such profits are acquired directly or through holding companies.

1. Transfer of Shares or Parts:

Exemption from any taxation of the transfer of shares or parts of Greek or foreign ship-owner companies, under Greek or foreign flags, regardless the reason of the transfer.

1. Transfer of Ships, Shares or Parts of Ship-owning companies:

–           Exempted from inheritance tax in case of transfer of ships, shares or parts of Greek or foreign companies owning ships under Greek or foreign flag, whose capacity exceeds 1.500 registered tons.

–           The same exemption applies for the shares or parts of intermediary holding companies.

(b)       Laws / Provision Amended

1. Article 26 of Law 27/1975

Contribution to Companies of Art. 25 of Law 27/1975

(a)       What Changes?

1. Imported Foreign Currency (2012-2015)

A contribution is imposedfor four (4) years, to the total annual imported foreign currency.

1. Subjects to the Contribution:

The branches and offices of foreign businesses dealing exclusively with:

• The exploitation, chartering, insurance, the settlement of averages, the brokerage of sales or freights or insurances of ships under Greek of foreign flag, exceeding 500 registered tons. Such activity for passenger ferry-boats and merchant ships covering local transports is excluded.
• The representation of ship-owner companies, as well as of businesses having the above mentioned activities.

1. Calculation of the contribution scales:

1. Law 27/1975 Offices and Branches:

Exemptionfrom the contributionforGreek and foreign companies who have established an office or branch under art. 25 of law 27/1975 and are dealing with the management or exploitation of ships under Greek or foreign flag, as well as undertaking any further activities, for which they have obtained a permit of establishment.

(b)       Laws / Provision Amended

1. Article 25 of Law. 27/1975

For any further comment or query on the above or any other issue, please liaise with your contact partner or you may liaise with the persons set out below who will refer you to the competent partner within KG.

Panagiotis Pothos

Elizabeth Eleftheriades

• Coordination Team
• Elisabeth V. Eleftheriades Partner
• E-mail: e.eleftheriades@kgdi.gr Tel: +30 210 817 1626
• Panagiotis Pothos                Senior Associate
• E-mail: p.pothos@kgdi.gr Tel: +30 210 817 1509

Contact Person in the UK

• Despina Doxaki  Partner
• E-mail: d.doxaki@kgdi.gr Tel: +0044 ( 0) 7881049978

www.kgdi.gr

This recapitulation first appeared in the company’s respective latest Tax Newsletter