Greece: Summary of a recent Supreme Administrative Court decision

Corporate income taxation of previously untaxed undistributed profits aligns with parent subsidiary directive

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September 4, 2025

The Supreme Administrative Court recently held that article 5 of the parent-subsidiary directive does not prevent corporate income taxation on previously untaxed undistributed profits upon distribution.

The court found that the Greek rule does not violate the directive's prohibition on withholding tax since it concerns the taxation of the income of the legal persons/entities themselves when they distribute or capitalize profits, and not the taxation of the distribution of profits to the parent company, referencing the CJEU's decision in Burda Verlagsbeteiligungen GmbH v. Finanzamt Hamburg-Am Tierpark (C-284/06).


For more information, contact a KPMG tax professional in Greece:

Antonia Ariel Manika | amanika@cpalaw.gr

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