tax

Tax

Kelemenis & Co. provides comprehensive and commercially driven legal advice on complex tax matters, supporting clients across the full spectrum of domestic and cross-border taxation. The firm combines technical expertise with a pragmatic understanding of business needs, advising on tax planning, regulatory risk management and the structuring of investments, corporate transactions and financing arrangements. The firm’s practice covers all aspects of direct and indirect taxation, including corporate income tax, VAT and customs, as well as the tax implications of intra-group transactions, cross-border payments and transfer pricing. The team regularly assists clients in navigating the evolving Greek and EU tax rules, ensuring compliance with applicable regulatory frameworks while optimising tax efficiency and mitigating risk. The firm has significant experience in tax controversy, representing clients at all stages of tax audits, administrative proceedings and judicial disputes, and advising on pre-litigation strategy and enforcement-related matters.

The firm’s expertise covers:

Establishment and Tax Organisation of Foreign Companies
in Greece

  • Market entry and structuring of presence in Greece
  • Tax support in setting up subsidiaries and branches
  • Selection of appropriate corporate and tax structures
  • Permanent establishment and tax presence

Tax Planning of Investments and Cross-Border Activities

  • Investment structuring
  • Tax burden optimization
  • Risk analysis and anti-abuse compliance (GAAR)

Direct and Indirect Taxation – Customs

  • Corporate income tax
  • VAT and intra-Community transactions
  • Customs and duties
  • Tax compliance and audits

Tax Regimes for Holding Structures

  • Holding company regimes
  • Participation exemption
  • Dividend and capital gains planning

Tax Structuring of Project Finance

  • Debt vs equity structuring
  • Interest limitation and thin capitalisation rules
  • Tax-efficient project finance structures

Cross-Border Payments

  • Taxation of interest, dividends and royalties
  • Application of Double Taxation Treaties (DTTs)
  • EU directives implementation
  • Withholding tax planning and exemptions

Transfer Pricing

  • Transfer pricing structuring and compliance
  • Documentation and reporting
  • Audit support and dispute management

Tax Due Diligence and Corporate Transactions

  • Tax due diligence
  • Group restructurings

Tax Audits & Pre-Litigation Strategy

  • Tax audits by the Independent Authority for Public Revenue (AADE)
  • Pre-litigation strategy

Tax Disputes (Direct & Indirect)

  • Disputes relating to direct and indirect taxation
  • Transfer pricing disputes

Administrative Tax Disputes

  • Administrative appeals (ενδικοφανείς προσφυγές)
  • Challenging tax assessments and penalties

Judicial Tax Disputes

  • Representation before administrative courts

Suspension of Enforcement & Interim Relief

  • Suspension of tax collection measures
  • Interim protection measures

Representative Clients

Chevron/Texaco, Public Gas Corporation (DEPA), General Electric, Energy Community Secretariat (Vienna), SEE-CAO, Edenred, Digital Charging Solutions (DCS), Gulf Perlite, Taxperience, Burger King, Hellenic Society for the Protection of Intellectual Property (AEPI), Cargill,  Farmeco (Coverdem),  The Athlete’s Foot, Metaxa, FTI Touristik GmbH, ABH Medical Group, Danaos Travel, Mouflon Investment Fund, KKR, Fieldcore, Eco Atlantic (Oil & Gas), Alstom, U-blox, Meeting Point, Anixe, DVS Technologies Inc, HAFCO

Representative Clients

Chevron/Texaco, Cargill, Shelman, Greek Transmission System Operator (TSO), Public Gas Corporation (DEPA), Energy Community Secretariat (Vienna), South East European Coordinated Auction Office (Montenegro), China Development Bank, Warwick Capital Partners, Baring Private Equity Fund, Metaxa, FTI Touristik GmbH.

Legal 500 2013 says:

Kelemenis & Co. handles the full range of tax issues. It represented Texaco in the Court of Appeal for a tax refund. Other clients include Chevron, GE, Metaxa, and Cargill. Tom Kyriakopoulos is recommended.

Tax Directors Handbook 2013 says:

Kelemenis & Co. is recommended for tax litigation and advisory work. It recently advised Chevron on tax compliance as well as the retrieval of refunds that were frozen by the Ministry of Finance. Tom Kyriakopoulos is a busy figure in the team.

World Tax Review 2012 says:

The tax team at Kelemenis & Co. is led by Tom Kyriakopoulos and consists of 5 fee earners. The practice provides a wide range of tax advice including M&As, transfer pricing, indirect tax and corporate finance.
This year the group has been advising Youtravel.com, an online tourism company, on a broad range of tax issues including indirect tax and transfer pricing issues. The group also advised the group on its cross-border restructuring.
Other work this year includes advising the sportswear manufacturer Champion Europe on the tax implications of various commercial agreements and working with Chevron Hellas Petroleum and Chevron Marine Products on their cross-border restructuring.

Chambers Europe 2011 says:

Tom Kyriakopoulos of Kelemenis & Co. receives consistently warm recommendations from clients. He is praised for his in-depth understanding of corporate tax matters and his ability to provide fast and detailed responses.

Legal 500 2011 says:

Kelemenis & Co.’s tax practice draws praise for the “professional, to-the-point” advice of Tom Kyriakopoulos. The group handles litigation, such as defending a client against the imposition of additional income taxes and penalties, as well as advising on the tax implications of transactions and corporate reorganisations, such as the closure of a number of Chevron’s local operations.

World Tax Review 2011 says:

Kelemenis & Co.’s “quality and organisation is closer to what you’d expect from a well-run Western European firm than a Greek one”. It was recently called on by The Energy Community secretariat to provide advice on direct and indirect tax issues for a joint venture in Montenegro. Tom Kyriakopoulos is “quick, business-minded and practical”.

Legal 500 2009 says:

Kelemenis & Co.’s tax practice has gone from strength to strength thanks to Tom Kyriakopoulos’s “significant tax expertise”. The firm has been providing tax advice on Barclays’ venture capital investment in a Greek company, which has involved the review of direct and indirect tax issues arising out of inter-group and third-party service agreements. Kelemenis & Co Law Firm providing services in all key corporate matters, and is able to support a broad range of tax advice.

Practice Areas