Greece is a civil-law jurisdiction, primarily based on written law, codes and statutes, rather than on binding case law. The main sources of law are the Constitution, legislation enacted by Parliament, codes such as the Civil Code, Criminal Code and Codes of Procedure, as well as European Union law.

The Greek courts are organised into separate branches. Civil courts deal with private disputes between individuals or legal entities, while criminal courts handle criminal offences. Administrative courts hear disputes between individuals or businesses and the State or public authorities.

At first instance, cases are heard by lower courts, depending on the nature and value of the dispute or the seriousness of the offence. Appeals are generally heard by courts of appeal. At the highest level, Areios Pagos acts as the supreme court for civil and criminal matters, while the Council of State is the supreme administrative court. The Court of Audit also has supreme jurisdiction regarding specific public finance matters.

Unlike common-law systems, Greek judges do not formally create binding precedent in the same way as UK courts. Their role is mainly to interpret and apply written law. However, decisions of Areios Pagos are highly influential and help ensure consistency in the interpretation of legislation. In particular, when Areios Pagos issues a judgment and refers the case back to a lower appeal court, this latter court is bound by the legal interpretation adopted by Areios Pagos in relation to the specific legal matter decided. Nevertheless, such rulings do not constitute generally binding precedent for all courts in future cases.

Overall, the Greek legal system reflects the civil-law tradition – ie, Parliament-made statutes and codified rules are the primary source of law, while case law plays an important supporting role in clarifying how those rules are applied in practice.

General Framework

Greece introduced its first standalone foreign direct investment (FDI) screening mechanism through Law 5202/2025 (the “Law”), implementing Regulation (EU) 2019/452 on the screening of foreign direct investments into the Union on grounds of security or public order. The regime became operational in November 2025 following the issuance of the implementing Joint Ministerial Decision No 64260/2025 regulating the notification process and supporting documentation.

The Greek FDI regime applies to investments by third-country investors, as well as by EU-based entities directly or indirectly controlled by third-country persons or governments.

The regime applies to both greenfield investments and acquisitions resulting in direct or indirect control, or qualifying minority participations, in businesses active in covered sectors.

Screening Criteria and Sectors

A filing obligation arises where the following cumulative conditions are met:

• The investor qualifies as a foreign investor.
• The target entity is incorporated under Greek law or otherwise carries out economic activity in Greece.
• The target operates in a designated sensitive or particularly sensitive sector.
• The applicable participation thresholds are met.

The Law distinguishes between “sensitive” and “particularly sensitive” sectors.

Sensitive sectors include energy, transport, health, information and communication technologies, and digital infrastructure. In these sectors, notification is generally triggered upon the acquisition of at least 25% participation rights, with additional filings required upon crossing certain higher thresholds.

Particularly sensitive sectors include defence, cybersecurity, artificial intelligence, critical port and submarine infrastructure, and certain tourism infrastructure located in border regions. In these sectors, the filing obligation is triggered at a lower threshold of 10%, reflecting heightened national security considerations.

The regime is mandatory and suspensory, in that transactions falling within its scope must be notified prior to completion.

Review Process

The review process is administered by the B1 Directorate of the Ministry of Foreign Affairs and the Interministerial Committee for the Screening of Foreign Direct Investments (ICSFDI).

The authority initially reviews whether the transaction falls within the scope of the regime and whether the filing is complete. Following referral to the Interministerial Committee, the authority may either clear the transaction at a preliminary stage or initiate an in-depth review.

Within 30 days of a complete filing, ICSFDI either clears the investment or opens an in-depth review. Following an in-depth review, ICSFDI submits a recommendation to the Minister of Foreign Affairs, who decides whether to approve, prohibit or condition the investment. If no decision is issued within 60 days from the date of ICSFDI’s recommendation, the investment is deemed approved.

The timetable may be suspended where additional information requests are issued.

Consequences of Non-Compliance

The regime imposes a mandatory pre-closing obligation. Failure to notify, late notification, or submission of inaccurate or misleading information may trigger significant sanctions:

• Failure to submit an application, or the submission of an application after its completion, may result in the imposition of mitigation or reversal measures by the authorities.
• These sanctions may be accompanied by a fine ranging from EUR5,000 to EUR100,000 (however, from the time the Law enters into force (23 May 2025) until the issuance and publication of the Joint Ministerial Decision on Fines, these administrative fines will not be imposed).
• Failure to submit the documentation required, as well as the submission of false information may result in the prohibition of the investment.

Proceeding with an investment despite an explicit prohibition, obtaining approval on the basis of false information, or failing to comply with the mitigation measures or the reversal of the investment imposed may result in a fine of up to twice the value of the investment.

A decision to prohibit, reverse, or impose conditions on an investment entails the automatic nullity of the relevant transaction, which may include reversal of the share sale agreement and any measures necessary to remedy the consequences of the transaction.

Although the regime is still new and no established enforcement practice has yet emerged, investors should approach filing obligations conservatively, particularly in infrastructure, technology, defence and data-driven sectors.

The Greek FDI regime allows the authorities to approve transactions subject to conditions or mitigation measures aimed at addressing national security or public order concerns.

Although the Law does not provide an exhaustive list of remedies, possible mitigation measures may include governance safeguards, restrictions on access to sensitive information or infrastructure, cybersecurity and data localisation obligations, continuity commitments and limitations on the transfer of strategic assets or technologies.

The authorities may also monitor compliance with imposed conditions and request information or supporting documentation from the parties.

Given that the Greek regime only recently became operational and that there is no published decisional practice, there are currently no clear indications regarding the authorities’ substantive approach to remedies or mitigation measures.

Law 5202/2025 does not establish a specific administrative appeal mechanism against FDI screening decisions.

However, as a matter of general Greek administrative law, final administrative acts may in principle be challenged before the competent administrative courts and, ultimately, before the Council of State.

The principal corporate vehicles used in Greece are the société anonyme (Ανώνυμη Εταιρεία – SA) and the private company (Ιδιωτική Κεφαλαιουχική Εταιρεία – PC), both providing limited liability. Among smaller enterprises, the limited partnership (Ετερόρρυθμη Εταιρεία – LP) is a commonly used vehicle.

Prior to the introduction of PCs in the Greek legal framework in 2012, the limited liability company (Εταιρεία Περιορισμένης Ευθύνης – EPE) was the most widely used vehicle for SMEs; however, given its more restrictive formalities (eg, mandatory notarial execution of its articles of association (AoA)), it has gradually fallen into disuse, and new EPE incorporations are rare in practice.

SA

Main characteristics

• A minimum capital of EUR25,000, paid in cash or in kind, is required.
• Capital is divided into registered shares; different classes may be issued (ie, ordinary or preferred shares).
• Shareholders’ liability is limited to their contribution.
• A single shareholder is permitted.
• It is managed by a board of directors or, in the case of non-listed small or very small SAs, by a sole director.
• Bond and warrant issuance is permitted.
• Shares may be traded on Regulated Markets.

The SA is the preferred vehicle for large operating companies, regulated entities, public companies and large-sized holding companies. Regulated activities (e.g. credit and financial institutions and investment services activities) may only be conducted through an SA. As a rule of thumb, an SA is more appropriate in case of many shareholders, external investors, or a large volume of business activities.

PC

Main characteristics

• There is no minimum capital requirement.
• Contributions are divided into company units.
• Partners may contribute through capital contributions, non-capital contributions (obligation to perform work or provide services), or guarantee contributions (assumption of personal liability to third parties up to a designated amount).
• Partners’ liability is limited to their contribution.
• A single partner is permitted (note: mandatory registration with the National Social Security Fund (e-EFKA)).
• It is managed by the administrator(s).

The PC is the most flexible and frequently used vehicle for SMEs, greenfield projects and a small or medium-sized Greek holding company due to its flexibility, low costs, and simplified governance.

LP

An LP consists of at least one general partner, with unlimited personal liability, and at least one limited partner, whose liability is limited to their agreed contribution.

Main characteristics

• There is no minimum capital requirement.
• The contributions of the partners may consist of their labour, money or other assets, as well as any other form of consideration.
• It is managed by its general partner(s).
• All partners must be registered with the e-EFKA.
• For LPs keeping single-entry books, distributed profits are exempt from dividend tax.

In the LP, partner identity is central to the company’s operation and object. Therefore, unless the partnership agreement provides otherwise, the partner’s death, bankruptcy, or legal incapacity will generally lead to the company’s dissolution, and any change in the partnership structure requires the remaining partners’ consent.

The LP is predominantly used by small enterprises and is unsuitable for regulated activities and large-scale operations, being preferred for activities with a low creditor exposure, such as the provision of services.

All company types follow a broadly similar incorporation process, completed either online through the E-One-Stop-Shop of the General Commercial Registry (GEMI) or before a notary public, serving as the one-stop-shop, by notarial deed, where required by law (eg, for in-kind real estate contributions) or agreed by the founders.

For online incorporation, the Model AoA (with either standardised or additional provisions) must be used, while for notarial incorporation, bespoke AoA may be used.

In all cases, the incorporation process is carried out in Greek and is completed within the same day. Online incorporation is more straightforward and cost-efficient, and upon completion, the company is automatically registered with GEMI, as well as with the tax and social security authorities.

Prior to incorporation, any foreign shareholder or partner, and any foreign director/administrator, must first register with the Greek tax authority and obtain a Tax Identification Number (TIN).

Under all of the above corporate forms, shareholders and partners may be either legal entities or individuals.

In addition to the incorporation fees, the incorporation of an SA is subject to a duty payable to the Competition Commission, amounting to 1‰ of the share capital.

Both the SA and the PC are subject to filing and disclosure obligations with GEMI, while LPs are subject to similar, albeit less extensive, compliance requirements.

Key obligations include:

• Management Changes/Changes to Representation Powers/AoΑ Amendment: Any change in legal representatives (including directors of SAs or administrators of PCs and LPs), any modification to representation powers and any AoA amendment must be registered with GEMI within 20 calendar days.

• Financial Statements: SAs and PCs are required to prepare annual financial statements under Greek Accounting Standards and to publish them via GEMI by the tenth calendar day of the ninth month following the end of the financial year. LPs keep single-entry books; accordingly, no such obligation applies to them, except for LPs keeping double-entry books (eg, LPs where all of their partners are limited-liability entities or their annual turnover exceeds EUR1,500,000).

• Single-Member Disclosure: Where an SA or PC has a sole shareholder or partner, the identity of that individual or entity is subject to publicity requirements on the GEMI website.

Further, Greek law requires companies to register their UBOs (ie, individuals holding an interest of at least 25% in the company) in the Central UBO Register. Initial registration and updates must generally be made within 60 days of the triggering event.

Greek companies operate on a one-tier management structure; Greek law does not provide for a formal two-tier supervisory/management model.

SA

It is administered by a board of directors (BoD) of three to fifteen members elected by shareholders.

SAs classified as “very small” or “small” may appoint a sole director-administrator (being a natural person), with the same duties and powers as a full board, provided that the AoA so permit.

A legal entity may be elected as a director, provided a specific individual is expressly designated to act on its behalf.

The BoD may delegate its powers to its members or to non-members, provided that such delegation is permitted under the ΑοΑ.

Board members who receive remuneration or hold at least a 3% participation in the company must be registered with e-EFKA.

PC

It is administered by one or more administrators, who must be individuals, elected by the partners.

Administrators may delegate certain responsibilities to one or more individuals provided that such delegation is permitted under the AoA.

Administrators must be registered with e-EFKA.

LP

It is managed and represented by the general partner(s). The partnership agreement, however, may assign such powers to a limited partner, who is then liable as a general partner for any act of representation, unless the third party was aware of their limited partner status.

Directors and administrators owe duties of care and loyalty to the company, assessed under a business judgment standard; those acting in good faith and in the corporate interest are typically protected from personal liability, though culpable acts/omissions or company debts, including unpaid tax and social security obligations, may attract personal liability. SA shareholders and PC partners are not liable beyond their contributions. Greek courts may exceptionally “lift the corporate veil” where the corporate form is abused to defraud creditors. In PCs, guarantee-contribution partners are directly liable towards third parties up to the AoA amount. In LPs, general partners bear unlimited liability; limited partners are liable only up to their agreed contribution.

Employment relationships in Greece are governed by the Greek Constitution, national legislation (ie, the Labour Code and the Civil Code, laws, presidential decrees and ministerial decisions), EU law and international treaties, as well as collective and individual employment agreements.

Case law is not a formal source of law but serves an interpretative function in applying statutory provisions.

The duration of the employment contract is agreed between the parties and may be either indefinite or fixed-term, on a full-time or part-time basis.

Fixed-Term Employment Agreements

A fixed-term contract may be renewed up to three consecutive times within a total period of three years and may not exceed an overall duration of three years. A break exceeding 45 calendar days is required to avoid consecutive fixed-term contracts being characterised as indefinite-term contracts.

Conclusion of Employment Agreements

There is no general legal requirement for employment agreements to be concluded in writing, except in specific cases (eg, part-time or temporary employment, renewal of fixed-term contracts).

Essential Terms of Employment

Although employment contracts do not generally need to be in writing, employers must provide employees with written information on their essential employment terms (job description, remuneration, working time, etc) within specific time limits (one week/month, depending on the information).

Maximum Working Hours

The statutory working time in Greece is eight hours per day, 40 hours per week, for employees under a five-day weekly work schedule, and six hours and 40 minutes per day (40 hours per week) under a six-day schedule, except for certain employee categories with reduced working hours.

The total weekly working time may not exceed, over a reference period of up to four months, an average of 48 hours, including overtime.

Overwork

Legal working hours may be exceeded by up to five hours per week (one hour per day under a five-day weekly schedule) due to workload. Under a six-day weekly schedule, overwork covers work performed between the 41st and 48th hour. Overwork is paid with a 20% surcharge on the hourly wage (unless an offset clause is included in the employee’s contract allowing set-off against the agreed salary exceeding the statutory minimum wage).

Overtime

Any work above the 45-hour limit and nine hours per day is “overtime”. Employees may perform overtime of up to four hours per day and up to 150 hours per year. Every hour of legal overtime is paid with a 40% surcharge on the hourly paid wage.

Overtime not complying with the statutory formalities and approval procedures is considered “illegal”, and employees are entitled to the hourly wage plus 120% for such overtime.

A special permit for overtime beyond the 150 hour limit may be granted by the Ministry of Labor, if justified for specific reasons and extraordinary work. Such overtime is paid with a 60% surcharge on the hourly wage.

The provision of paid time off in lieu of statutory overwork or overtime compensation is not permitted.

The parties may agree that the part of the employee’s salary exceeding the statutory minimum can be offset with overwork compensation; however, such offsetting is not allowed for overtime compensation. 

Work During Sundays/Public Holidays

Employees may not work on Sundays or public holidays, unless legally exempt. Compensation amounts to 75% on top of the legal hourly wage. In urgent cases, such work may be authorised by the authorities; otherwise, it is considered as “illegal”. If work exceeds five hours on Sunday, the employee is entitled to a day off.

Work on the Sixth Day

For employees under a five-day weekly schedule, work on the sixth day is not permitted and the employees are entitled to receive an increase of 30% on their normal hourly wage.

By exception, employees of undertakings of continuous operation with rotating shift systems, or undertakings which are not of continuous operation but may operate on a six-day (24/5 or 24/6) shift basis, may be required to work on the sixth day. Prior notification to the Labour Inspectorate and registration through the ERGANI II platform are required, and work is limited to eight hours (no overwork/overtime permitted), and is remunerated with a 40% surcharge on the hourly wage.

Night Work

Night work is from 22.00 until 06.00 and is compensated with a 25% increase in the hourly wage.

Executive Employees

Under Greek law, only executive employees are exempt from working time provisions and are therefore not entitled to compensation for overwork or overtime. Executive employees are managerial employees, as defined by law, declared as such in the ERGANI II platform, and employed under a contract reflecting their status.

Termination of Indefinite-Term Contracts

Requirements

Termination of indefinite-term employment agreements does not require a “serious cause”; however, in case of litigation, the employer must demonstrate that the termination was justified and the “last resort”.

The validity of the termination requires:

• written notification of the employee;
• payment of the severance amount; and
• employee’s registration with the competent social security fund.

Where the employee has committed a criminal offence and the employer has filed a complaint, termination without severance may take place. In the event of the employee’s acquittal, statutory severance becomes payable.

Employers are also required to notify the labour authorities.

Notice period

The employer may terminate the employment with prior notice or immediate effect. Where the statutory notice period is observed, the employee’s severance is reduced by 50%.

Severance payment

The statutory severance in Greece consists of the basic severance, applicable to all employees on indefinite contracts, and the additional severance, applicable to employees who, as of 12/11/2012, have completed 17 years of service with the employer.

Basic severance amount (and applicable notice period) depends on the employee’s length of service with the employer and is capped at 12 monthly salaries. It is calculated on the employee’s total regular monthly remuneration of the last month before termination, multiplied by 14 (to include statutory allowances), and divided by 12, to produce a monthly average. Additional benefits provided regularly, without reservation of amendment or revocation, should also be included.

Employees who, as of 12 November 2012, had 17 years of service with the same employer are entitled to additional severance of one monthly salary per year beyond 17 years, up to 12 monthly salaries, based on last month’s earnings under full employment, capped at EUR2,000.

Termination of Fixed-Term Contracts

Fixed-term contracts are terminated automatically when their agreed term expires. Early termination is permitted for a “serious cause”, without notice or severance. In the absence of serious cause, all salaries due until the initially agreed expiration date are payable.

Redundancies

Any type of redundancy is considered a justified reason for dismissal. However, the employer should be able to demonstrate, in potential litigation, that the position was genuinely made redundant and that selection complied with statutory criteria. Available alternatives (eg, redeployment) should be assessed before termination.

Selection criteria apply to comparable employees and include performance (the prevailing criterion), seniority, age, family burdens, financial status and the possibility of finding a new job.

Collective Dismissals

Specific provisions exist for collective dismissals. The procedure is triggered where an employer with 20-150 employees dismisses more than six employees in a calendar month, or where an employer with more than 150 employees dismisses more than 5% of its workforce and, in any event, more than 30 employees in a calendar month.

Specific information and consultation requirements exist for collective dismissals, as well as notifications to the Ministry of Labour. Failure to follow the prescribed procedure renders the dismissals null and void.

The general rules on valid termination and severance continue to apply.

The establishment of employee representative bodies and participation therein is not generally mandatory and is exercised where the relevant legal requirements are met. Employee representation is primarily exercised through trade unions and works councils.

Trade Unions

Union membership is a fundamental right under the Greek Constitution, ensuring employees’ freedom to organise and advocate collectively. Any adverse treatment, including dismissal, due to union involvement is prohibited.

Trade unions are structured at three levels:

• first-level unions (sectoral, occupational or company-level unions; local branches; and associations of persons);
• second-level organisations (federations and labour centres); and
• third-level confederations of federations and labour centres.

The establishment of a trade union requires at least 20 employees. Founding members apply for recognition to court, upon which the union acquires legal personality.

Trade unions aim to preserve and promote employees’ labour, financial, insurance, social and collective interests. Their main rights include collective bargaining and the right to strike, as well as information and consultation rights in cases of collective dismissals, transfer of undertakings, restructuring, the introduction of new technologies, etc.

Works Councils

Works councils may be formed in enterprises employing at least 50 employees, or more than 20 employees, where no trade union exists. They are elected by employees and consist of three, five, or seven members, depending on the size of the workforce.

Their primary function is advisory, with information and consultation rights regarding matters affecting employees, including health and safety, introduction of new technologies, collective redundancies, transfers of undertakings and restructuring measures (in the absence of a trade union).

European Works Councils

For multinational enterprises, European Works Councils are established for the protection of employees’ rights in a broader, multinational form. Employees from all countries in which the enterprise is engaged participate in an EWC.

A taxpayer may be subject to taxation either based on their tax residence or because they derive income from a Greek source. Accordingly, any person who is considered a tax resident of Greece is subject to tax on their taxable income arising both in Greece and abroad earned during a specific tax year, whereas a taxpayer who is not a tax resident of Greece is subject to tax only on taxable income arising in Greece and earned during the relevant tax year. However, domestic law provisions apply subject to any double taxation treaty.

With respect to taxes imposed in the context of an employment relationship, employees are subject to progressive income tax brackets, while employers are liable for withholding such (payroll) tax and social security contributions calculated on the employee’s income.

The following tax rates apply to the employee’s income, from 1 January 2026 onwards, subject to applicable reductions:

• From EUR0 to EUR10,000, the tax rate is 9%.
• From EUR10,000.01 to EUR20,000, the tax rate is 20%.
• From EUR20,000.01 to EUR30,000, the tax rate is 26%.
• From EUR30,000.01 to EUR40,000, the tax rate is 34%.
• From EUR40,000.01 to EUR60,000, the tax rate is 39%.
• For income over EUR60,000, the tax rate is 44%.

With regard to tax breaks/incentives available for employees, from FY 2021, a taxpayer/employee who transfers their tax residence to Greece may qualify for a special tax regime if certain conditions are met, including prior non-residence in Greece and relocation from an eligible country (ie, an EU or EEA member state or from a state with which Greece has an administrative co-operation agreement in the field of taxation in force). Under this regime, 50% of employment income earned in Greece is exempt from income tax for up to seven tax years.

Under domestic tax rules, a company is subject to corporate income tax either based on its tax residence or if it maintains a permanent establishment under domestic rules or applicable double tax treaty provisions. Accordingly, a company is considered tax resident in Greece and subject to tax on its worldwide income if any one of the following conditions is met; in essence, a company is regarded as tax resident in Greece if it has been incorporated or established under Greek law, or if it has its registered seat in Greece, or if its place of effective management (POEM) is located in Greece for any period during the tax year.

With regard to taxable income and applicable tax rates, a Greek company and a permanent establishment are subject to corporate income tax at a rate of 22%, after deducting business expenses, provided that all the relevant conditions provided for the deduction under the Greek Income Tax Code (GITC) are met, as well as depreciation and provisions for doubtful receivables (with respect to a permanent establishment, subject to the provisions of any applicable double tax treaty, which may override domestic provisions).

Taxable business profits are generally determined on the basis of accounting profits, as adjusted by the specific rules and classifications set out in the GITC. In principle, they correspond to total revenues minus deductible business expenses, tax-allowable depreciation, and certain provisions for bad debts. As a rule, incorporated businesses are taxed on an accrual basis, while any profits not previously taxed become taxable upon distribution or capitalisation.

Withholding Tax on Income: Interest, Royalties, Dividends

Income derived from interest, royalties, and dividends falls under the general category of investment income and is subject to withholding tax at a rate of 20% for Greek-source royalties, 15% for Greek-source interest, and 5% for dividends, subject to the provisions of any applicable double tax treaty) or, where applicable, the provisions of the EU Interest–Royalties Directive and the Parent–Subsidiary Directive.

In short, dividend exemption applies where the conditions of the EU Parent–Subsidiary Directive are met, including a minimum 10% participation held for at least 24 months, qualifying EU tax residency and inclusion in Annex I companies, as well as subject-to-tax requirements without exemption options; similarly, exemption from withholding tax on interest and royalties applies to payments between qualifying EU associated companies where a minimum 25% direct or indirect participation is held for at least 24 months, and the beneficiary satisfies the requirements of the EU Interest and Royalties Directive regarding qualifying entity status, EU tax residence (without third-country treaty residence), and full corporate tax liability without option or exemption. Until the minimum holding period is completed, a bank guarantee may be provided for the withholding tax due, instead of immediate payment of the withholding tax and subsequent refund claim.

A special anti-avoidance rule prohibits the withholding tax exemption on the qualifying dividend payments where the relevant exemption is claimed in the context of artificial arrangements.

Pillar 2 Directive, Law 5100/2024

Greece has implemented EU Council Directive 2022/2523 (Pillar Two Directive) through Law 5100/2024, establishing a global minimum taxation framework for multinational groups and large-scale domestic groups.

Under this regime, the GloBE Information Return (GIR) must generally be filed within 15 months after the end of the relevant reporting fiscal year (or 18 months for the transitional year). The corresponding tax return must then be filed by the last working day of the month following the submission of the GIR.

The law introduces the QDMTT safe harbour, the CbCR transitional safe harbour, and the UTPR transitional safe harbour. It also expressly provides that these safe harbours are to be interpreted in line with the OECD Model Rules.

VAT Considerations

VAT is imposed on all transactions for consideration involving the supply of goods and the provision of services. The standard VAT rate is 24%, although reduced rates also apply in certain cases.

Digital Transaction Duty (DTD)

The DTD is a tax introduced in Greece through Law 5135/2024 and codified by Law 5177/2025, imposing a proportional levy on specific transactions that fall outside the scope of VAT. The DTD applies to transactions where at least one party is a Greek tax resident or has a permanent establishment in Greece, provided that the transaction is connected to that establishment. The duty is calculated as a specific percentage of the financial value of the transaction or the highest debit/credit balance.

Special Real Estate Tax (SRET)

The ownership of Greek real estate through non-transparent structures is addressed through the imposition of a special tax on property held as of 1 January each calendar year, calculated at a rate of 15% on the imputed/statutory value of the real estate. In practice, the tax does not apply to a significant number of incorporated entities holding real estate in Greece due to various exemptions, particularly where the owning company is not considered to be used as a vehicle for tax evasion or avoidance. Recent amendments to the special real estate tax framework have aligned the exemption for regulated investment vehicles with applicable domestic and EU legislation governing such schemes.

Unified Real Estate Tax (URET)

The URET (ΕΝ.Φ.Ι.Α.) constitutes an annual property tax imposed on all real estate situated in the country. It is calculated on the basis of objective property values, considering factors such as floor area, age, and location, with main tax rates for buildings ranging from EUR2 to EUR16.20 per square metre.

Capital Concentration/Accumulation Tax

CCT is levied at a flat rate of 0.2% on contributed capital, including share capital increases made in cash or in kind. This duty applies to commercial companies and corporate transformations, rather than to the initial establishment of a company.

Listed Shares Sales Tax

Capital gains arising from the sale of listed and unlisted shares are treated as business income and are subject to corporate income tax at the standard CIT rate. However, where such gains are realised by foreign legal entities tax resident abroad, they are taxable in Greece only to the extent that the entity maintains a permanent establishment in Greece to which such gains can be attributed. In addition, the transfer of listed shares is subject to a transaction duty at a rate of 0.1%.

Incentives Offered for All Enterprises

The GITC introduces tax incentives in the form of enhanced “super” deductions for specific business expenses. Scientific and technological research costs, including depreciation of related equipment, are deductible with a 100% uplift. Similar enhanced deductions apply to expenses related to the green economy, energy efficiency, and digitalisation for SMEs, as well as to costs connected with the listing of SME shares or equivalent securities on a regulated Greek market, also with a 100% uplift and a cap on the resulting tax benefit of EUR200,000. The provision aims to encourage investment in research, sustainable development, digital transformation, and capital market participation.

Digital Business

Greece provides a broad set of tax incentives that may be relevant to digital businesses. Expenditure on scientific and technological research, including depreciation of relevant equipment and instruments, is deductible with an additional 100% uplift. Following amendments introduced by Law 5162/2024 (applicable from FY 2025), this enhanced deduction rises to 150% for eligible research costs linked to collaborations with entities registered in the National Startup Registry, accredited research centres, and universities that are independent from the recipient of the services, as well as for depreciation of research-related equipment. In certain cases, SMEs may benefit from an increased deduction of up to 215%.

Furthermore, GITC establishes a “Patent Box” regime, which allows, subject to specific conditions, tax exemption for income generated from self-developed, internationally recognised patents. Greece also offers a favourable regime for angel investors, providing income tax relief for certified investments in qualifying start-ups.

Corporate Transformations

Corporate reorganisations, including mergers, demergers, transformations, spin-offs, and contributions of assets, are governed by two parallel legislative frameworks. From a corporate law perspective, Law 4601/2019 provides a comprehensive framework regulating all forms of corporate transformations. From a tax law perspective, rules have recently been introduced to consolidate and modernise the tax provisions and incentives applicable to corporate reorganisations (Articles 47–59 of Law 5162/2024), replacing the previously fragmented framework under Laws 1297/1972, 2166/1993, 2778/1998, and 4172/2013. At the same time, the incentive regime introduced by Law 4935/2022 – primarily aimed at micro, small, and medium-sized enterprises (SMEs) – remains in force. In addition, the special restructuring framework applicable to credit institutions under Law 2515/1997 continues to apply.

Special Regime of Law 89/1967

Under Law 89/1967, a favourable regime is available to foreign companies operating in Greece that provide specific services to their parent companies, affiliated entities, or other non-Greek businesses, including consultancy, accounting support, quality control, planning, marketing, data processing, and similar activities. In essence, such entities are required to determine their gross revenues on a cost-plus basis, calculated by adding a pre-approved profit margin to total operating expenses and tax-allowable depreciation, excluding income tax, following an audit or review by the competent Committee. The profit margin is set by a committee appointed by the Minister of Development and Investments and is reassessed every five years, subject to significant changes in market conditions.

No response was provided in this jurisdiction.

Interest deductibility in Greece is limited under the thin capitalisation (interest limitation) rules set out in GITC. Under these provisions, net interest expenses are generally deductible up to 30% of EBITDA (calculated on a tax basis). Any amount exceeding this threshold is not deductible in the relevant tax year. However, disallowed net interest expenses can be carried forward indefinitely and deducted in future tax years.

An exemption applies where net interest expenses do not exceed EUR3 million, in which case the limitation does not apply. In addition, certain entities – such as credit institutions, insurance and reinsurance companies, and pension institutions – are excluded from the scope of these rules.

In Greece, transfer pricing is mainly regulated under the GITC, supplemented by administrative guidance from the Independent Authority for Public Revenue (IAPR). In addition, the Tax Procedure Code sets out the framework governing tax audits as well as the documentation and procedural requirements applicable to transfer pricing compliance.

Furthermore, the OECD Transfer Pricing Guidelines are recognised and applicable in Greece as an interpretative framework for applying the relevant legal provisions. In particular, the GITC stipulates that the arm’s length principle must be applied and interpreted in line with the general principles and the OECD Transfer Pricing Guidelines in relation to intra-group transactions.

Transfer pricing rules apply to transactions between “related parties” as defined under the GITC. Greek tax legislation adopts a broad definition of related parties, covering both direct and indirect relationships that may influence the pricing of intra-group transactions. In more detail, a 33% threshold is applied to determine related-party status, based on direct or indirect participation in capital or voting rights. In addition, parties may also be treated as related where one entity exercises managerial control or decisive influence over another, regardless of whether any participation in capital or voting rights exists.

Greece has introduced Controlled Foreign Corporation (CFC) rules, a General Anti-Abuse Rule (GAAR), and hybrid mismatch provisions in accordance with ATAD I and II, whereas there are special anti-avoidance rules regarding the taxation on corporate transformations.

The GAAR applies to both domestic and cross-border arrangements, provided that the relevant double tax treaty does not contain its own anti-abuse provisions, such as a Principal Purpose Test. Under this rule, the Greek tax authorities may disregard arrangements or series of arrangements that are primarily, or have as one of their main purposes, the obtaining of a tax advantage that contradicts the intent or purpose of the applicable tax law.

Under the revised CFC framework, even where all applicable conditions are met, the rules will not apply if the foreign entity is located in an EU or EEA jurisdiction and demonstrates genuine economic activity, such as having sufficient staff, premises, assets, and equipment.

Lastly, the hybrid mismatch rules aim to prevent double deductions or deductions without corresponding taxation arising from differences in the tax treatment of entities or instruments across jurisdictions, thereby safeguarding against base erosion.

Greece, as part of the European Union, is subject to the Union Customs Code (UCC). The aforementioned code was adopted in 2013, and its substantive provisions have applied since 1 May 2016, with the aim of bringing EU customs legislation into line with the requirements of the Lisbon Treaty. It supersedes the former Community Customs Code (CCC).

Having said that, tariff classification is governed by the Combined Nomenclature (CN) and specific tariff classification decisions and updates are formally adopted through Commission Implementing Regulations. The European Commission updates this list on an annual basis, with the most recent revisions adding specific subheadings for advanced technologies such as batteries, photovoltaics, hydrogen, and advanced materials (Commission Implementing Regulation (EU) 2026/360 and Commission Implementing Regulation (EU) 2026/333).

Countries with extensive trade agreements with the European Union benefit from significantly reduced or eliminated tariffs, creating heavily integrated market access. For example, the EU–South Korea Free Trade Agreement has eliminated customs duties on nearly all goods traded between the parties. In addition, it has reduced numerous non-tariff barriers affecting exports of products such as automobiles, pharmaceuticals, electronics, and chemicals. The agreement has also liberalised a wide range of services sectors, facilitating market access and investment opportunities for both EU and South Korean businesses. Another example is the EU–Central America Association Agreement, which has been provisionally applied since 1 August 2013 with Honduras, Nicaragua, and Panama; since 1 October 2013 with Costa Rica and El Salvador; and since 1 December 2013 with Guatemala.

Greek merger control is governed by Law 3959/2011 (the “Greek Competition Act”), which is closely aligned with the EU Merger Regulation (EUMR). The system is primarily administered by the Hellenic Competition Commission (HCC) and operates on a mandatory and suspensory basis. In the electronic communications and postal sectors, competition law enforcement powers are exercised exclusively by the Hellenic Telecommunications and Post Commission (EETT) within its sectoral remit.

Transactions Covered

The Greek merger control regime applies to concentrations resulting in a lasting change of control.

Notifiable transactions include:

• mergers between previously independent undertakings;
• acquisitions of sole or joint control over all or part of a business; and
• the creation of “full-function” joint ventures performing on a lasting basis all functions of an autonomous economic entity.

The concept of control is interpreted consistently with EU merger control principles and may arise through shareholdings, contractual arrangements or veto rights.

Jurisdictional Thresholds

A concentration must be notified to the competent competition authority prior to implementation where the following cumulative turnover thresholds are met:

• The combined aggregate worldwide turnover of all undertakings concerned exceeds EUR150 million.
• At least two undertakings concerned each generate turnover exceeding EUR15 million in Greece.

The Greek regime is exclusively turnover-based and does not provide for market share thresholds.

Transactions meeting the EU thresholds fall within the exclusive jurisdiction of the European Commission unless referred to the HCC under the EUMR referral mechanisms.

Filing and Pre-Notification

Notification must be submitted prior to completion of the transaction. Although not mandatory, pre-notification contacts are frequently used in complex cases to discuss jurisdictional and procedural issues, as well as substantive matters.

Within seven working days after the filing, the HCC shall assess whether the notification form is incomplete and request the parties concerned to provide additional information. If they fail to submit complete and precise information as requested, the one-month time limit of Phase I does not commence; thereby, the progress of the procedure is delayed. In practice, it is common that the competent competition authority demands additional information, resulting in a delay of the procedure for 10 to 15 additional days.

Phase I Review

The HCC conducts an initial review within one month from receipt of a complete filing.

During Phase I, the authority may:

• determine that the transaction falls outside the merger control regime;
• clear the concentration unconditionally; or
• initiate an in-depth Phase II investigation where serious competition concerns are identified.

Requests for additional information are common in practice and may suspend or delay the review timetable.

20 calendar days after the notification date, the parties may also offer commitments intended to address potential competition concerns.

Phase II Investigation

Where the HCC opens an in-depth investigation, the statutory review period is generally 90 days from the decision initiating Phase II. The case is brought before the HCC within 45 days from that decision, and remedies may be proposed within 20 days from the case being brought before the HCC.

The Phase II investigation period is automatically extended by 15 days, if the parties propose remedies later than the 20-day limit. Thus, the maximum duration of Phase II is 105 days.

The authority may ultimately:

• approve the transaction unconditionally;
• clear it subject to remedies; or
• prohibit the concentration.

If the HCC fails to issue a decision within the applicable statutory deadline, the concentration is deemed approved.

Gun-Jumping and Sanctions

The Greek merger control regime prohibits implementation prior to clearance.

Failure to notify a notifiable transaction, early implementation (“gun-jumping”), or breach of remedies may result in significant administrative fines. The HCC also has powers to impose behavioural or structural measures where necessary.

Legal Framework

Article 1 of the Greek Competition Act mirrors Article 101 TFEU and prohibits agreements, decisions by associations of undertakings and concerted practices that have as their object or effect the restriction of competition. Typical infringements include price-fixing, market sharing, output restrictions, bid-rigging and exchanges of commercially sensitive information.

The Greek Competition Act also recognises in its Article 1(3) the equivalent of the Article 101(3) TFEU exemption, allowing restrictive agreements where efficiency gains outweigh anti-competitive effects and consumers receive a fair share of the resulting benefits. EU Block Exemption Regulations also apply mutatis mutandis to agreements, decisions or concerted practices which are not likely to affect trade between EU member states.

Additional National Rules

Greek law also prohibits invitations to collude and certain unilateral disclosures of future pricing intentions by large undertakings (Article 1A of the Greek Competition Act).

Territorial Scope

Greek competition law follows the effects doctrine. Under Article 46 of the Greek Competition Act, the regime applies to anti-competitive conduct capable of affecting competition in Greece, irrespective of where the conduct occurred or whether the undertakings involved are established in Greece.

Accordingly, agreements concluded or implemented outside Greece may still fall within the jurisdiction of the HCC where they produce actual or potential effects on the Greek market.

Abuse of Dominance

Article 2 of the Greek Competition Act mirrors Article 102 TFEU and prohibits abusive conduct by undertakings holding a dominant position in the Greek market or a substantial part thereof.

Unlike the EU system, Greek law expressly allows settlement procedures not only in cartel cases but also in abuse of dominance investigations.

As with cartel enforcement, the Greek abuse of dominance regime is based on the effects doctrine. Under Article 46 of the Greek Competition Act, abusive conduct may fall within Greek jurisdiction where it takes place in Greece or produces actual or potential effects on the Greek market, regardless of the location of the undertaking concerned. This allows the HCC to investigate foreign undertakings whose conduct materially affects competition in Greece, even absent a physical presence in the jurisdiction.

Abuse of Economic Dependency

Greek law separately prohibits the abusive exploitation of economic dependency (under Article 18a of the Unfair Competition Act (Law 146/1914)), which may exist where a trading partner is substantially reliant on a commercial relationship and lacks an equivalent alternative.

Article 18a is enforced exclusively by the Greek civil courts, which may order the cessation of the abusive conduct and/or its non-repetition, award damages (actual loss and/or loss of profits) and impose fines of EUR5,000 to EUR50,000 on responsible natural persons. Furthermore, any agreement giving rise to the abusive conduct is void under Article 174 of the Greek Civil Code.

Foreign undertakings without a principal establishment in Greece may invoke Article 18a only if reciprocity is established, namely if Greek undertakings enjoy equivalent protection in the relevant foreign jurisdiction. Accordingly, beyond the existence of effects of the conduct in Greece, Article 18a is subject to an additional limitation, with reciprocity restricting access to protection under the provision.

Definition

A patent is an intellectual property right protecting technical inventions that are novel, involve an inventive step and are capable of industrial application. The main applicable framework in Greece is Law 1733/1987.

Length of Protection

Patents are protected for 20 years from the filing date, subject to annual renewal fees. Protection may be extended by up to five years for medicinal and plant protection products through a supplementary protection certificate.

Registration Process

Patent protection in Greece may be obtained through the following:

• National Patents: An application is filed with the Hellenic Industrial Property Organization (OBI). Following formal examination and a search report, OBI grants and publishes the patent.
• European Patents (European Patent Convention): A European patent application may be filed with the European Patent Office (EPO), designating Greece. Once granted, the patent must be validated in Greece by OBI.
• International Patents (Patent Co-Operation Treaty): Applicants may file an international application with OBI or WIPO. Upon entry into the European phase and grant of the European patent, the above validation process applies.

Greece has signed but has not yet ratified the Unified Patent Court Agreement.

Enforcement and Remedies

Patent rights are enforced primarily through civil proceedings, including injunctions, damages and the removal or destruction of infringing products. Damages may be based on lost profits, reasonable royalties or the infringer’s profits. Information claims and publication of court decisions are also available.

Definition

A trade mark is any sign capable of distinguishing the goods or services of one undertaking from those of another and of being represented on the register with clarity and precision.

Length of Protection

Protection in Greece is available through:

• national trade marks (Law 4679/2020);
• EU trade marks – EUTMs (Regulation (EU) 2017/1001); and
• international registrations under the Madrid Protocol.

Protection lasts ten years from the filing date/from the date of international registration and may be renewed indefinitely for successive ten-year periods.

Registration Process

A national trade mark application is filed with OBI. Upon its formal examination, the application is published and becomes subject to a three-month opposition period. If no opposition is filed, or any opposition is rejected, the trade mark is registered. A similar procedure applies to EUTMs before the European Union Intellectual Property Office (EUIPO).

For international registrations, the application is filed through the applicant’s national or regional office and submitted to the World Intellectual Property Organization (WIPO). Following formal examination by WIPO, the designation of Greece is notified to OBI, which examines the application under national law. In the absence of a refusal, the mark enjoys protection in Greece as a national trade mark.

Enforcement and Remedies

Enforcement includes:

• cease and desist letters;
• civil proceedings seeking injunctions, damages and measures such as recall, removal or destruction of infringing goods;
• interim measures;
• criminal liability in counterfeiting cases;
• customs enforcement measures; and
• opposition, revocation and invalidity proceedings.

Signs that have acquired distinctive character through use may also enjoy protection without registration.

Definition

Industrial designs, governed mainly by Presidential Decree 259/1997, protect the appearance of the whole or part of a product, provided it is new and has individual character.

Length of Protection

Registered designs are protected for five years from filing, renewable for successive five-year periods up to a maximum of 25 years.

Unregistered Community designs are protected for three years from first disclosure within the EU.

Registration Process

Protection is available through the following:

• National Designs: An application is filed with OBI. Following formal examination, OBI issues a registration certificate and the registered design is subsequently published.
• EU Designs (Regulation (EU) 2024/2822): Applications are filed with EUIPO and follow a similar registration procedure to national designs.
• International Design Registrations (Hague System): A single international application may be filed with WIPO, designating Greece. Following publication in the International Register and absent refusal, the design enjoys protection as if registered nationally.

Enforcement and Remedies

Right holders may seek cessation of the infringement, injunctions against future infringements and damages. Courts may also order withdrawal, removal from the market or destruction of infringing goods. A design may additionally qualify for trade mark and/or copyright protection where applicable.

Definition

Copyright is an intellectual property right granted to original literary, artistic or scientific works in any form, including both economic and moral rights. The main applicable framework is Law 2121/1993.

Length of Protection

Copyright lasts for the author’s life plus 70 years, calculated from 1 January of the year following the author’s death.

Registration Process

In Greece, copyright is not subject to registration. Protection arises automatically upon creation of the work.

Enforcement and Remedies

Enforcement mechanisms include:

• civil actions, including injunctions and damages;
• interim measures;
• criminal sanctions; and
• administrative enforcement measures, including notice-and-takedown procedures for digital content.

Software is protected as a literary work under copyright law, covering source and object code. Software-related inventions may be patentable if they produce a technical effect.

Databases are protected through:

• a sui generis right, where there has been substantial investment in obtaining, verifying or presenting the contents; and
• copyright protection, where the selection or arrangement of the contents constitutes an original intellectual creation.

Law 4605/2019 protects trade secrets. Protection requires that the information be secret, have commercial value and be subject to reasonable confidentiality measures.

Sources of Data Protection Law in Greece

• System Overview: The Greek data protection framework is based on a combination of constitutional provisions, EU law, national legislation, and regulatory guidance. Overall, the system is characterised by the primacy of the GDPR, supplemented by national laws and extensive regulatory guidance, including sector-specific lex specialis rules.
• Constitution: At the constitutional level, the Greek Constitution establishes core safeguards: Article 9A guarantees the protection of personal data and mandates an independent authority, while Article 19 protects the confidentiality of communications.
• GDPR and National Implementing Legislation: The primary legal instrument is the General Data Protection Regulation (GDPR), which is directly applicable in Greece and establishes the general rules on lawful processing. It is supplemented by Law 4624/2019, which implements the GDPR, transposes Directive (EU) 2016/680 and regulates the operation of the Hellenic Data Protection Authority (HDPA). The framework is further complemented by the residual provisions of Law 2472/1997, which had originally transposed Directive 95/46/EC into the Greek legal order. Notably, the Hellenic Data Protection Authority has clarified, in Opinion 1/2020, that national provisions which conflict with the GDPR, or which lack a valid legal basis under its opening clauses, should not be applied.

• Relevant and Sector-Specific Regulation: The framework is complemented by relevant and sector-specific laws, notably:
1. Law 3471/2006 on electronic communications (cookies, direct marketing, soft opt-in and opt-out rules);
2. Law 5002/2022 (confidentiality of communications);
3. Law 5086/2024 and Law 5160/2024 (cybersecurity); and
4. Law 5169/2025, and Law 4961/2022 (emerging technologies).
• Role of Supervisory Authorities: Competent supervisory authorities, such as the HDPA, issue binding decisions, guidelines, and recommendations, which play a key role in interpreting and enforcing the framework.

Cross-Border Application of Data Protection Law

• Territorial Scope Under the GDPR: The applicability of Greek and EU data protection rules in an international context is primarily governed by the GDPR territorial scope (Article 3). The GDPR applies not only to controllers and processors established in Greece or elsewhere in the EU, but also to non-EU entities where their processing activities relate to the offering of goods or services to individuals in Greece, or the monitoring of behaviour of individuals within Greece (eg, through tracking technologies or profiling). Accordingly, a foreign company targeting customers in Greece (eg, via a Greek-language website) will be subject to the GDPR.
• Supervisory Authority and One-Stop-Shop Mechanism: Enforcement is carried out by the HDPA where Greece is the relevant jurisdiction (eg, where data subjects are located or where a local establishment exists), subject to the GDPR’s one-stop-shop mechanism for cross-border processing.

Data Protection Authority and Regulatory Enforcement Framework

The Hellenic Data Protection Authority

Data protection in Greece is enforced primarily by the HDPA, established under Law 2472/1997 and operating within the framework of the GDPR, Law 4624/2019 and Law 3471/2006. The Authority exercises a broad range of powers, including monitoring compliance and issuing guidelines and recommendations.

Enforcement activity is largely complaint-driven, although the HDPA also initiates ex-officio investigations in cases of broader public interest. Proceedings before the HDPA follow administrative procedures and typically involve the preparation of a case file, a hearing, and the issuance of a reasoned, binding decision after the parties have been heard.

Where a breach of data protection law is established, the HDPA exercises its corrective powers, including the imposition of administrative fines. Decisions of the HDPA are binding but may be challenged before the Council of State (see also below).

Enforcement trends

Recent enforcement practice indicates an increasing focus on high-risk areas, including employment-related processing and data breaches. Violations of data subject rights remain a consistent priority, with particular emphasis in the past year on the right of access.

Looking ahead, greater emphasis is expected on transparency obligations, in line with co-ordinated enforcement actions of the European Data Protection Board and the participation of the HDPA therein.

Other relevant authorities

The Hellenic Authority for Communication Security and Privacy is responsible for safeguarding the confidentiality of communications. It issues regulations, conducts audits, and investigates complaints, particularly in relation to telecommunications and lawful interception.

The Hellenic Cybersecurity Authority is responsible for cybersecurity oversight. It supervises the implementation of the NIS2 framework and co-ordinates incident reporting at the national level.

In the financial sector, additional supervisory responsibilities arise under the Digital Operational Resilience Act. These are exercised by authorities such as the Bank of Greece and the Hellenic Capital Market Commission, which oversee digital operational resilience and ICT risk management.

Judicial proceedings

• Civil Law – Compensation Claims: Individuals whose data protection rights are infringed may seek judicial protection before the civil courts. Claims may include compensation for both material damage (eg, financial loss) and non-material damage (eg, distress or reputational harm). Courts assess compensation on a case-by-case basis, considering factors such as the nature and seriousness of the infringement and the impact on the individual.
• Criminal Proceedings: Greek law provides for criminal liability in cases of serious violations of data protection legislation. Criminal proceedings are conducted before the competent criminal courts, either following a complaint by the affected individual or upon initiation by the public prosecutor.
• Administrative Proceedings: Decisions of the HDPA are binding on the parties concerned; however, parties whose rights or interests are affected may challenge such decisions before the Council of State.

Explanatory Note: The above avenues of redress operate independently; none is contingent upon the initiation of another.

Merger Control: More Interventionist Enforcement and Procedural Modernisation

The most significant development in Greek merger control is not legislative but enforcement-driven. Recent cases suggest that the HCC is increasingly willing to subject transactions affecting concentrated domestic markets to rigorous scrutiny and, where necessary, require far-reaching remedies or allow transactions to be abandoned. This trend was illustrated by the proposed EUR217 million acquisition by Allwyn International of a controlling stake in Novibet’s parent company, Logflex MT Holding. Following the issuance of a Statement of Objections in December 2025, the parties abandoned the transaction in March 2026 (HCC Decision No 904/2026). The HCC’s concern was the elimination of OPAP’s only meaningful competitor in the Greek online betting market. This follows the HCC’s prohibition of the Alphabet/Delta transaction in July 2025, its first merger prohibition in over two decades. Parties considering acquisitions in concentrated sectors, particularly involving digital markets or the elimination of a key competitive constraint, should expect rigorous scrutiny. At the same time, Greece is continuing to modernise its merger control framework. Recent amendments have simplified certain procedural aspects of the notification process and further aligned domestic practice with EU standards. An additional point to watch will be the interaction between Greek enforcement practice and the European Commission’s ongoing review of the EU Merger Guidelines. While the Commission’s draft guidelines emphasise innovation and efficiencies, recent HCC decisions reflect a comparatively cautious approach to consolidation in concentrated markets, a divergence that may become particularly relevant where jurisdiction could fall to either authority.

Foreign Direct Investment Screening: From New National Regime to European Harmonisation

The most significant development in the field of foreign investment is the introduction of Greece’s first comprehensive foreign direct investment (FDI) screening mechanism under Law 5202/2025, coupled with the ongoing reform of the EU FDI screening framework. As the regime is still in its infancy, a key issue for market participants will be how the competent authorities interpret and apply the new framework in practice, particularly with respect to jurisdictional questions, substantive assessment criteria and the types of mitigation measures that may be imposed. Further refinement of the recently enacted national framework is expected as the EU’s new FDI Screening Regulation – approved on 8 June 2026 and expected to take full effect by early 2028 – will require member states to maintain screening mechanisms meeting common minimum standards and to extend mandatory screening to a broader set of strategic sectors – including artificial intelligence, quantum technologies, advanced semiconductors, electoral systems, designated financial entities and strategic raw materials. Investors should therefore expect the Greek FDI regime to remain a developing area over the next several years, with additional implementing measures and administrative guidance likely to emerge as both domestic and EU rules evolve. From a transactional perspective, deals involving strategic assets or sensitive sectors will increasingly require parallel merger control and FDI screening reviews, alongside any sector-specific regulatory approvals.

Reform of Greek Succession and Family Law

Whilst not directly relevant to the sections set out above, it is worth noting that with Law 5303/2026 published in the Government Gazette on 22 May 2026, Greece has enacted its most comprehensive reform of succession and family law in eight decades. This reform is expected to give a boost to the attractiveness of Greece as a jurisdiction for high-net-worth individuals, family offices, and internationally mobile wealth. Combined with the existing non-dom tax regime and the Golden Visa programme, the reform adds a further dimension to Greece’s offer as a destination for wealth relocation and long-term investment.