Tax Updates: December 10th 2025

The recently voted Law 5246/2025 introduced new incentives for investments in strategic sectors of defense and the manufacture of vehicles, aircraft and related machinery, as well as components and equipment thereof. The regime is aligned with the EU General Block Exemption Regulation (GBER), which determines when certain types of government support (State Aid) are considered compatible with the internal market. Under this framework, eligible projects include initial investments in defined manufacturing sectors (with defined Business Activity Codes) such as manufacturing of weapons and ammunition, construction of motor vehicles and military combat vehicles and of their components and equipment, construction of aircrafts and associated machinery.

The incentives are provided in the form of:

• Tax benefit (super-deduction of investment expenditure /
  super-depreciation of fixed assets)
• Fast-track licensing
   

Key considerations of the new regime

Eligibility

All enterprises (regardless of size) with registered seat or branch in Greece, which make initial investments in eligible projects within 2026, 2027 or 2028, may be eligible for the above incentives upon submission of relevant application.
 

Tax incentive (super-deduction / super-depreciation)

The new incentive provides for the deduction from gross revenues of enterprises, according to the provisions of the tax legislation, of eligible expenditure incurred by enterprises for eligible investment projects increased by 100%, thus effectively resulting in a 200% deduction, unless the amount of the benefit exceeds a certain cap threshold. Namely, the amount of the benefit claimed each year cannot exceed half of the total benefit granted for the investment project.

Eligible expenditure includes any investment expense paid for tangible and intangible assets that will be used for the above-mentioned manufacturing activities.

Depreciation of capital assets may also qualify as eligible expenditure provided that increased depreciation is not already applied in accordance with some other provisions of the Income Tax Code (ITC) and on condition that the criteria of the EU Regulation are in any case met.

The right to use the tax incentive (super deduction) is established at the time of commencement of the investment project and the incentive can be used within fifteen (15) tax years from the tax year in which the right to use the incentive was established.

If the investment is not maintained in the eligible region, for which it was granted, for at least five (5) years following completion, the tax benefit may be revoked and the amount of the already claimed super-deduction shall be returned in accordance with State Aid recovery rules.
 

Loss carry-forward

Losses generated because of the super-deduction may be carried forward according to the general provision of the ITC.
 

Entry into force

The procedure and conditions for inclusion under the new incentives regime, submission of the relevant application, evaluation, audit, as well as other details and any restrictions of the new regime will be determined by a Joint Ministerial Decision of the Minister of National Economy and Finance and the Minister of Development. The new incentives regime will come into effect upon issuance of this joint decision and will apply to expenses incurred as of 1 January 2026 onwards.