Practice area

World TP Reviews

Transfer pricing

Deloitte’s transfer pricing team has 20 fee earners. Because of the BEPS directive, many multinational groups have undergone restructuring and Deloitte is expanding its service offering dedicated to a post-BEPS environment. This includes a diagnostic review regarding post-transfer pricing restructuring, as well as APAs and MAPs. Fotis Tsamparlis, partner, heads the transfer pricing team.

The firm assisted a Greek group company with restructuring its operations to comply with the BEPS directive. The task involved identifying tax risks for the proposed business model, designing a new TP policy and more.


EY has one the largest transfer pricing teams in Greece with 32 fee earners. The firm is active and dominant in sectors such as insurance, pharmaceuticals, healthcare, travel, telecommunication, media and entertainment. Transfer pricing documentation services is its core business. However, the firm also offers APA controversy services such as administrative assistance, judicial procedural developments with the court, technical assistant providing and filing documents, and appeals against APA assessments defending its clients’ APA strategy from pre-ruling to post-ruling.

The team assisted a food and beverage company in obtaining a €350 million APA with the tax authority, which is one of the first post-BEPS-era concepts.

Zepos & Yannopoulos

Zepos & Yannopoulos’s transfer pricing practice is led by Elina Filippou, which has five members: two lawyers and three economists. The team offers a wide range of transfer pricing services, such as the design of transfer pricing strategy, economic analysis of transactions, APAs, dispute resolution and more. In addition, the law firm also has the expertise and capability to advise and prepare transfer pricing documentation. Cross-border reorganisations of Greek operations is an area in which the firm has gained a depth of experience.

The firm advised Deca Investment Managers with tax due diligence and pre-acquisition transfer policy for the target company. The reorganisation of the TP policy involved restructuring of intangibles and preparing TP documentation.