We successfully represented a leading Greek betting and gaming company before the Administrative Supreme Court (Council of State – “CoS”) at a model (“pilot”) tax trial, on which a landmark Decision under No. CoS 320/2020 was issued. The Court accepted our arguments and annulled the tax assessment acts. In particular, it ruled that, for tax years 2011-2013 and as concerns the right of the Greek State to make a tax audit, article 82 (5) of Law 2238/1994 (former ITC) and the implementing Ministerial Decision (“MD”) Νο 1159/2011 provide for a valid settlement/closure of the relevant tax cases after a 18-month period, following the issuance of a “clear” tax certificate. Such a settlement is a valid tax regime in accordance with the Greek Constitution.
Our firm has advised a consortium of two Greek banks in the negotiation, signing and subscription of a €15mn bond loan issued by EVROFARMA S.A., a listed in ASE corporation, leader in the dairy industry market.
We successfully represented a high-net-worth individual before the Administrative Supreme Court (Council of State, major 7-member composition, CoS Decision No 2691/2019). The Court accepted our arguments concerning the implementation of the principle of retroactive application of the more lenient law in the domain of tax penalties.
Our firm has advised a consortium of four Greek banks in the negotiation, signing and subscription of a €41mn bond loan issued by A&G PAPER S.A., a leading corporation in the paper industry market.
Our firm has advised Piraeus Bank in the negotiation, signing and subscription of five bond loans of a total value of €140mn issued by TERNA ENERGY S.A., a corporation listed to the ASE, and four of its subsidiaries.
Our firm has advised a consortium of Greek banks in the negotiation, signing and subscription of a €6,5mn bond loan issued by a subsidiary of AKRITAS SA, a corporation listed to the ASE active in the wood products sector, within the framework of the latter’s bank debt restructuring.
We successfully represented a high-net-worth individual before the Administrative Supreme Court (Decision No CoS 732/2019 - Council of State) at a model (pilot) tax trial concerning the statutory limitation period of the Greek State to impose taxes, and, in particular, the duration of the limitation period in the event of late tax return filing.
We successfully represented before the Court of Appeal a Greek member-company of major automobile multinational group at a stamp duty tax dispute (Decision No 4661/2018). The Court annulled the tax assessment acts on the basis that the cash pooling agreement was both signed and executed abroad; therefore, no obligations were executable within Greek territory in order for the stamp duty to be due.
We successfully represented before the Court of Appeal a major football Societe Anonyme at a capital concentration tax (“CCT”) dispute of EUR 0,85 m (Decision No 2860/2018). The Court ruled that CCT is triggered by the decision of the Board of Directors certifying the payment of the capital increase and not by the decision of the GM resolving upon the increase.