Smaro Anagnostou

Smaro is one of the leading experts on taxation in Greece. She advises corporate and institutional clients, including investment funds, on the structuring and tax treatment of inbound and outbound investments, mergers and acquisitions, restructurings and insolvencies, privatizations, and commercial agreements.

As well as advising on the tax implications of, and the most efficient structures for, executing major corporate transactions and investments, Smaro also advises clients on real estate and other forms of asset ownership, the effect of double taxation treaties, and the direct and indirect taxation (including vat) implications of local and cross-border transactions, financing techniques and transfer pricing.

She is also experienced in Litigation & Dispute Resolution, supporting clients in disputes with the Greek tax authorities and before the courts.

Working closely with our employment practice, she also supports clients in matters relating to executive and employee remuneration.

Notable Tax - Corporate cases

• Advised BriQ REIC on profit distribution ratios, and extraordinary income – capital gains distribution, according to reic special legislation and ongoing changes in the law, commenting on the Ηellenic Fund and Asset Management Association’s relative opinion.
• Advised BriQ REIC on the execution and tax implementation of distribution of shares to company’s executives, under the newly enacted tax exemptive provisions on shares/ shares option schemes; communication to this effect with the Greek Capital Markets Committee, facilitated the transposition of applicable rules to processes and documentation in place by the Committee.
• Advised BriQ REIC a Greek registered reic, on corporate – tax law compliance issues regarding the distribution of advance dividends by related parties, and the tax treatment of lease payments deriving from covid-19 subsidies and tax relief measures in place for the amount of €1,5m.
• Advised Whirlpool Hellas before the tax authorities and Administrative Courts, in its dispute with the tax authorities regarding the assessment of stamp duty for tax years 2013 and 2014 for the amount of €1,5m.
• Advised Whirlpool Hellas on tax compliance re write off of overdue receivables – bad debts, taking into consideration recent changes in applicable legislation, not yet fully clarified, and the group’s credit policy and practices to this effect for the amount of €6m.
• Advised Goodyear Tyres on tax issues arising in the course of its daily operations; call-off stock arrangements business restructuring between the group companies in Europe, and their impact on corporate and VAT taxation were examined; compliance with Greek rules transposing EU VAT provisions on the subject matter recently enacted, and corporate taxation rules were examined to discuss due implementation in Greece.
• Advised Wind Hellas, one of the leading Greek telecommunications’ companies, on the tax treatment of the bond loan issue, acting for the financial institutions.
• Advised Align Technology, a US orthodontics company, on structuring its Greek activities and operations; advice was sought with respect to permanent establishment issues under DTT signed by Greece, resale obligations under income tax law, and employer and employee taxation under the DTTs and national law.
• Advised an investment management company, on the tax issues related to the structuring of the acquisition and immediate resale of a Greek bank’s portfolio of real estate assets, to non-identified end buyers, via the assignment of pre-contract rights for the amount of €7,5m.
• Advised a HNWI, acting via his UK investment entity, on its tax dispute with the Greek tax authorities, re its special real estate tax and ubo tax registration obligations, resulting in the confiscation of prime real estate held for the amount of €6,5m.