Tax Treaty Case Law around the Globe 2013

S. 151. Introduction

In recent years, primarily due to the financial crisis, a number of additional fiscal or parafiscal charges have been introduced in Greece, under various names and of various types. The present case concerns one of the first of such charges, the one-off extraordinary social responsibility contribution imposed by Article Five of Law 3845/2010 on the total net profits of corporate taxpayers reported in financial year 2009.

This special contribution is a one-off levy, imposed on all corporate taxpayers that had total net profits over EUR 100,000.00 in financial year 2009. Corporate taxpayers with total net profits of less than the EUR 100,000.00 threshold were totally exempted. For the taxpayers covered by the provisions, the contribution was based on the whole amount of the total net profit; the EUR 100,000.00 did not function as a tax-free amount.

The contribution was calculated on the total net income according to the following progressive tax rates, applicable in the respective income brackets:

The total net profit of corporate taxpayers for the purposes of this specia...