Tax in Transition: Perspectives from the 2025 Athens Tax Forum
Business Partners, Jan-Feb, 2026

Cross-border intra-group transactions have a material impact on the financial outcomes and tax obligations of multinational enterprises (MNEs). Transfer pricing rules continue to undergo substantial changes, and tax authorities have intensified their scrutiny, leveraging AI-driven tools, resulting in substantial assessments and foreign tax adjustments.

Well-structured transfer pricing policy reduces risk and ensures alignment between policy, operational reality, and financial reporting

The adoption of artificial intelligence across industries is transforming business models, while the introduction of public country-by-country reporting adds a new level of scrutiny. At the same time, in light of the current global trade environment, many MNEs are reevaluating where they manufacture, hold intellectual property, and distribute products to foreign markets, as well as how they structure their intra-group services and how they support the benefit test.

The start of 2026 has already introduced further developments, with the OECD issuing new administrative guidance on Pillar Two, introducing the side-by-side safe harbor (with the United States as the first qualifying jurisdiction), alongside a simplified-effective-tax-rate safe harbor and a substance-based-tax-incentive safe harbor, all of which are central to the interactions between OECD rules, the EU’s Minimum Tax Directive, and member states’ incentive regimes as implementation and compliance frameworks continue to evolve.

These changes present both challenges and opportunities, and the question emerges: What should MNEs do to ensure their transfer pricing (TP) policies remain accurate, relevant, and compliant?

MNEs should establish robust transfer pricing strategies. They must reevaluate whether their TP strategies are fit for purpose and align with where value is created globally within their respective groups; they must ensure that their TP policies are robust and evolve in line with business and regulatory developments. TP policies should be formalized through well-drafted intercompany agreements, and TP documentation must be prepared in accordance with the specific requirements of each jurisdiction.

A well-structured and clearly articulated TP policy reduces the risk of disputes and controversy, provides a defensible position during tax authority challenges, and ensures alignment between policy, operational reality, and financial reporting.

Furthermore, MNEs should support their transfer pricing with data and technology. Tax authorities are now looking beyond TP policy language, examining how transfer prices are calculated, how they reconcile with financial results, and how closely intercompany agreements align with actual facts.

In this environment, MNEs should strengthen their approach by leveraging technology for automated data collection. They should use AI to enhance efficiency, accuracy, and consistency, cloud-based platforms to enable real-time data access, scenario modelling, forecasting, and streamlined compliance, and analytics systems to compute transfer prices and identify risk areas.

Lastly, MNEs should stay informed and be ready to respond to change. They must continuously monitor global and local transfer pricing developments, including trends in disputes raised by tax authorities, proactively identifying audit risks, making use of advance pricing agreements (APAs) where transactions are significant and of high risk, and consistently being prepared to defend their TP policy effectively during tax audits.

In a world of accelerating regulatory change and global supply chain transformation, MNEs must ensure their transfer pricing framework is robust, data-driven, and aligned with where value is truly created.

In today’s business landscape, the way organizations manage pricing between related entities—commonly referred to as transfer pricing—is undergoing a profound transformation. What was once a routine compliance task is now recognized as a strategic function with far reaching implications for cash flow, profitability, and resilience.

Several forces are driving this shift. The acceleration of digitalization, the emergence of new business models, and the reconfiguration of global supply chains have made intercompany transactions more complex and visible. At the same time, tax authorities are leveraging advanced analytics and real-time data, increasing both the frequency and depth of audits. In Greece, for example, recent regulatory changes and heightened scrutiny around management fees, intercompany loans, and royalties have raised the stakes for companies operating across borders.

When aligned with business strategy, transfer pricing becomes a lever for value creation, not just compliance

This transformation is not happening in isolation. As organizations expand internationally and business models become more digital, the complexity of intercompany transactions increases. Finance leaders are recognizing that pricing policies between related entities are no longer just about meeting regulatory requirements. Instead, these policies are being woven into the fabric of financial planning and operational strategy. By considering the impact of these arrangements early in the decisionmaking process, companies can anticipate effects on liquidity, margins, and overall business performance.

Technology is playing a pivotal role in this evolution. Automation and real-time data analytics are enabling organizations to monitor outcomes continuously, rather than relying on annual reviews or retrospective adjustments. This shift allows for greater agility, as companies can identify and address issues as they arise, rather than reacting to surprises at year-end. The integration of these tools into enterprise resource planning systems is also helping to ensure that data used for compliance is consistent with the information used for management and reporting.

Governance and risk management are now central to this new approach. Cross-functional teams, often including tax, finance, and treasury professionals, are now standard practice for overseeing policy and execution. Regular reviews and clear documentation help reduce audit risk and ensure compliance with evolving regulations. In Greece, frameworks such as Law 89 are providing new opportunities for tax certainty and operational stability, but they also require ongoing attention to detail and process discipline.

The strategic importance of these policies extends beyond compliance. They influence the outcomes of mergers and acquisitions, affect capital allocation, and support scenario analysis for business model changes. When aligned with broader business objectives, these arrangements can unlock value, manage risk, and support sustainable growth.

The landscape is changing, and so is the role of transfer pricing. No longer just a defensive shield, it has become a strategic steering wheel—helping organizations design financial outcomes, anticipate challenges, and steer confidently through uncertainty. By embedding these practices into everyday decisionmaking, organizations can move from compliance to value creation, turning complexity into opportunity and building a foundation for sustainable growth. That’s how you stay ready for what’s next.

Taxation is undergoing a significant transformation, evolving from a back-office compliance function to a central driver of value creation and investment appeal. This is fueled by seismic changes in the global tax framework, rapid advancements in digital technology, and increased regulatory scrutiny.

Greece is uniquely situated to tap into its tax framework as part of a national strategy aimed at drawing new investment capital, supporting fiscal expansion, and encouraging private sector engagement.

Success will require a streamlined, reliable, and strategically aligned tax landscape with incentives for heavy growth sectors

Findings from the EY Tax Survey Greece 2025 highlight the mounting pressures on tax and finance departments across the country, which are now navigating more stringent regulatory demands. Over half of the tax leaders surveyed identified compliance with the Greek tax technology requirements – such as e-invoicing, e-transportation documents and the transmission of invoices/characterizations to the myDATA platform (the IAPR’s Digital Accounting and Tax Application) – as their top priority. The prioritization of compliance requirements, however, appears to be coming at the expense of the advisory role of tax and finance functions toward the company’s leadership. Notably, 37% of respondents expressed concern that they are unable to adequately advise the business given the complexity and unpredictability of the global tax landscape and the Greek tax environment. Such insufficient capacity to support broader business decisions reveals a systemic tilt toward compliance over value creation and risk management.

On the other hand, 65% of executives reported a greater risk or uncertainty around tax legislation or regulation generally in the past two years, driven by intensified audits, complex reporting, and frequently changing regulations. In this context, tax stability and predictability could prove to be crucial competitive advantages. In our recent survey on foreign direct investment in Greece (EY Attractiveness Survey Greece 2025), 40% of participants regarded tax framework certainty as a top factor for enhancing Greece’s appeal to foreign investors.

The opportunities lie ahead. The convergence of tax expertise, technological innovation, and skilled talent is redefining what tax functions can achieve. The increasing adoption of technologies such as artificial intelligence, robotic process automation (RPA), and advanced analytics is expected to drive performance improvements. However, 20% of tax departments still face challenges integrating with IT, limiting their ability to capitalize on digital strategies and align tax with broader business goals.

There is also a growing focus on transparency and real-time data flows, particularly through tax certification regimes, such as Article 65A of the Tax Procedures Code (L.4174/2013), that foster compliance, trust, and proactive risk management.

With macroeconomic stability, ongoing reforms, and heightened investor interest, this is a pivotal moment for Greece. Success will require a streamlined, reliable, and strategically aligned tax landscape, with incentives for growth-heavy sectors such as R&D, sustainability, innovation, and digital. Simplifying regulations, fostering collaboration, investing in talent, and treating tax as a foundational growth piece are essential steps for ensuring Greece’s longterm success.

 

The revisions to the Commentary on Article 5 in the 2025 Update to the OECD Model Tax Convention provide essential clarity on fixed place of business permanent establishments in the context of cross-border remote working, particularly home offices. These revisions expand on prior limited guidance into a new section, spanning a massive 21 paragraphs with multiple examples, driven by the COVID-19 pandemic’s acceleration of remote work trends. Since the treaty text remains unchanged, the revisions enable immediate application to OECD-based treaties without amendments.

The aim of the update is to modernize guidance by applying established principles to contemporary setups. Key principles persist: “Fixed” requires permanency (generally over six months), preparatory or auxiliary activities are excluded (Article 5(4)), and dependent agent rules apply separately (Article 5(5)). The Commentary now acknowledges workers operating from homes, second homes, holiday rentals, or relatives’ places in a different state from the enterprise, with unique features such as individual control and limited enterprise access.

The amendments to the Commentary on Article 5 matter profoundly for Greece’s post-pandemic economy

Furthermore, a pivotal time-based indicator states that if an individual uses a home office or similar place for less than half of their total working time for the enterprise over a 12-month period (beginning or ending in the fiscal year), it will not be a place of business and thus no fixed place permanent establishment. This safe harbor simplifies common cases, with exceptions rare in this context. For periods exceeding half the total working time, the core question is whether a commercial reason exists, meaning whether the individual’s presence in that state facilitates the enterprise’s business through direct engagements with customers, suppliers, associated enterprises, or others there.

Commercial reasons include local meetings, on-site services such as training, repairs for state customers, or real-time interactions across time zones, such as a State R enterprise using a State S home worker for 24/7 customer support during European daytime. No commercial reason applies if engagements are intermittent or incidental, home use is solely to retain the employee without geographic ties, or purely to cut costs like office space. Multiple motives? One commercial reason suffices.

Illustrative examples reinforce the above: A State R employee works from a State S home for one or two days a week over 12 months: fixed due to permanency, but below 50% time threshold means no place of business or permanent establishment. Another example involves a State R employee in State S working 60% from home, serving multi-state customers remotely, with quarterly client visits: fixed and over threshold, but visits are incidental, so no commercial reason and no permanent establishment.

These amendments matter profoundly for Greece’s post-pandemic economy, where remote work contributes substantially to GDP without eroding the tax base. Immediately binding for all Greek OECD-aligned treaties, they demand that domestic enterprises and foreign hosts implement time-tracking and rationale documentation to mitigate double taxation threats. By harmonizing flexibility with predictability, the OECD’s update positions Greece advantageously in global talent wars, provided stakeholders adapt proactively to facts-driven assessments.