Greece: Greek tax treatment of foreign private foundations

Abstract The concept of foreign foundations pursuing statutory purposes other than charitable purposes does not exist in Greek civil law and is also not expressly recognized in Greek inheritance and gift tax law. On the other hand, from a Greek income tax point of view, Article 2 of the Greek Income Tax Code, applicable as of 1 January 2014, explicitly includes foundations of any type within the definition of legal entities. Moreover, in July 2017, the Greek Ministry of Finance issued Guidelines regulating the Greek tax treatment of foreign foundations of a non-charitable nature, which until then was entirely a matter of interpretation due to the lack of relevant legal provisions. This has resulted in trusts and foreign private foundations now being accorded similar tax treatment under the relevant Guidelines.