The agreement of 18 April 1966 between the Federal Republic of Germany and the Kingdom of Greece for the avoidance of double taxation remains in force unchanged.
However, since 1 April 2021 it has been modified by the BEPS Multilateral Instrument (MLI), which introduces, among other things, a new preamble and an anti-abuse clause. The Federal Ministry of Finance publishes a consolidated “synthesised text” on this, combining the agreement and the MLI, which should be treated as authoritative for practical application.
For context: this agreement is one of more than 55 double taxation agreements Greece has concluded with other states, including all other EU member states; readers with tax matters connecting Greece to a country other than Germany should consult the relevant agreement for that country, or our general overview of Greece’s double taxation agreements.
Principal Content of the Agreement
In its basic structure, the agreement follows the classic format of bilateral double taxation agreements of that period and governs, in particular:
- the taxes covered (in Germany: income tax, corporate income tax and net wealth tax, as well as trade tax; in Greece: the income tax of natural and legal persons),
- the residence of natural persons and companies, and the tie-breaker rules in the case of dual residence,
- the concept of a permanent establishment and the allocation of business profits,
- the taxation of dividends, interest, royalties, capital gains, and income from employed and self-employed work,
- the avoidance of double taxation through the credit or exemption method, and
- the mutual agreement procedure between the competent authorities of both states.
The agreement remains in force for an unlimited period; it may be terminated by either contracting state with effect from the end of a calendar year. For application in individual cases – in particular the precise allocation of taxing rights under the respective articles – we recommend always referring to the complete, MLI-consolidated text of the agreement published by the Federal Ministry of Finance.
FAQ
Covered, on the German side, are income tax, corporate income tax and trade tax (the former net wealth tax has not been levied in Germany since 1997), and on the Greek side, the income tax of natural persons and of legal persons. The agreement also applies to future taxes of an identical or substantially similar nature.
A natural person is generally regarded as resident in the state in which they have a permanent home available to them. Where they have a permanent home available in both states, the centre of vital interests is decisive. Failing that, habitual abode and, ultimately, nationality apply.
A company is regarded as resident in the contracting state in which its place of effective management is located. The same applies to partnerships and other bodies of persons that are not legal entities under the domestic law applicable to them.
A permanent establishment is a fixed place of business through which the business of the enterprise is wholly or partly carried on (e.g. a place of management, a branch, an office, a factory, a workshop, a mine, or a building site or installation project lasting more than 12 months).
Not regarded as a permanent establishment are, among other things, storage, exhibition or delivery facilities, and fixed places of business used solely for purchasing, gathering information, advertising, scientific research, or similar preparatory or auxiliary activities.
The business profits of an enterprise of one contracting state may be taxed only in that state. However, if the enterprise carries on business in the other state through a permanent establishment situated there, the profits attributable to that permanent establishment may be taxed in the other state.
Dividends, interest and royalties may in principle be taxed in the recipient's state of residence, with the source state retaining a limited right of taxation. The tax withheld in the source state is generally credited in the state of residence.
The Germany – Greece DTA combines the exemption and credit methods: certain income is exempted in the state of residence (where applicable, subject to the progression proviso), while other income is taxed with credit given for the tax paid in the source state.
On the Greek side, the Ministry of Finance is competent; on the German side, the Federal Ministry of Finance.
The term “retirement benefit” refers to periodically recurring payments made for past services or as compensation for damage. “Pension” refers to an amount payable at regularly fixed times, either for life or for a specified period. Taxation is governed by the corresponding provisions of the DTA.
As of June 2026. All information on these pages is provided without guarantee or liability.