Making Transfer Pricing Adjustments Effective: Are the Tax Authorities Obliged to Reopen Fiscal Years for Which Corrective Tax Assessments Have Been Issued, after a Full Tax Audit?

Abstract

After a recent amendment to the Greek Tax Procedure Code (Law 4174/2013), the tax authorities now have the right and duty to reopen years for which the tax obligation has been finalized after a full tax audit has been conducted and a corrective tax assessment has been issued, only in cases where it obtains new information and only provided that the correction leads to the assessment of additional tax for the fiscal years in question. The author examines the effect of this provision on cross-border transfer pricing audits.