Greece: Super-deduction regime to support investment in defense-related and allied manufacturing units
Applicable to expenditures incurred on or after January 1, 2026
The Ministry of Finance on November 11, 2025, published Article 13 of Bill 5246/2025, introducing a new regional aid regime aimed at supporting investment in defense-related and allied manufacturing units, including a 100% super-deduction for qualifying capital expenditure.
The regime operates in line with Commission Regulation (EU) 651/2014, the General Block Exemption Regulation (GBER), and sets the conditions under which certain categories of State aid are to be considered compatible with the internal market. Under this framework, eligible projects include initial investments in defined manufacturing sectors such as weapons and ammunition, motor vehicles and components, aircraft and associated machinery, and military equipment.
Key takeaways include:
- Eligibility: The measure applies to all enterprises (regardless of size) that have a registered seat or branch in Greece and make investments in eligible projects, as defined in the GBER. The initial investment must be made in 2026, 2027, or 2028, and needs to be maintained in an eligible region for at least five years following completion. Non-compliance may result in the revocation of the tax benefit, with the amount of the claimed super-deduction becoming repayable in accordance with State aid recovery rules.
- Calculation: The super deduction amounts to 100% of the eligible expenditure in tangible and intangible assets (effectively resulting in a 200% deduction), unless the amount of the benefit exceeds a certain cap threshold. Depreciation of capital assets may also qualify as eligible expenditure provided the assets meet the GBER criteria.
- Loss carry-forward: Losses generated through the enhanced deduction may be carried forward for up to 15 tax years following the investment year.
The application procedure will be established by a joint decision of the Minister of National Economy and Finance and the Minister of Development, and the scheme will apply to expenditures incurred on or after January 1, 2026.
Read a December 2025 report prepared by KPMG’s EU Tax Centre