An Israeli Company Operating in Greece: Branch or Subsidiary, Permanent Establishment, VAT, Employing Staff and an Annual Compliance Calendar

An Israeli company that sells to Greece, provides services there, manages a project or opens a local team needs to decide on the structure through which to operate. The decision affects the liability of the Israeli company, tax in Greece and in Israel, reporting, and the ability to sign contracts and employ staff. This guide compares the options and explains the main obligations, as of November 2026.

1Through what structure can an Israeli company operate in Greece?

There are four main ways: direct activity from Israel, a registered branch, a Greek subsidiary, and a services office under Law 89. According to Deloitte Legal's review, a foreign company may in principle operate in Greece directly, but a physical presence in Greece may require registration. It is also possible to work through commercial agents and distributors.

2When does direct activity from Israel become a permanent establishment in Greece?

When the company has a fixed place of business in Greece, a dependent agent concluding contracts on its behalf, or a building site lasting more than three months, under Greek law as summarised by PwC (as of November 2026). Greek law defines a permanent establishment according to the OECD Model: a fixed place of business through which the company's business is carried on, such as an office, a branch, a factory or a place of management. A building site, installation or assembly project is a permanent establishment after only three months, compared with 12 months under the OECD Model. A dependent agent who concludes contracts on behalf of the company may create a permanent establishment, whereas an independent agent, such as a broker, usually does not.

Where a permanent establishment is created, the profit attributed to it is taxed in Greece at 22%, and registration, bookkeeping and reporting obligations arise. The tax treaty between Israel and Greece may set different rules, for example on the duration of a building site, so before a project in Greece the text of the treaty should be checked. Details on tax are in the guide to Israel's tax treaties.

3How is a branch of an Israeli company registered in Greece?

A branch is registered in the General Commercial Registry (GEMI) under Articles 39 and 43 of Law 4919/2022, and is managed by a legal representative appointed by the Israeli company who acts on its behalf in Greece. The representative needs a Greek tax number. The branch is not a separate entity, so every obligation it incurs is an obligation of the Israeli company.

1. A board resolution of the Israeli company to open the branch and appoint the legal representative and set his powers.
2. Preparing the company documents: certificate of incorporation, articles, a current company extract and details of the controlling persons, with an apostille and a certified Greek translation.
3. Obtaining a Greek tax number (AFM) for the legal representative and, where necessary, for the company itself.
4. Filing the registration documents with GEMI.
5. Registering with the tax office, including VAT registration if the branch makes taxable transactions.
6. Opening a bank account, appointing an accountant and registering as an employer if staff are employed.

4Is a local manager or representative needed in Greece?

The manager does not have to be a Greek resident or citizen: Greek law has no residence or citizenship requirement for the managers of a subsidiary, and in a branch a legal representative appointed by the company acts on its behalf in Greece. However, every manager, director and authorised signatory needs a Greek tax number, and in practice it is common for the main authorised signatory to have a presence in Greece for day-to-day operations. A non-EU manager who intends to live in Greece needs an appropriate residence permit.

A manager's presence in Greece also has a tax side: a manager in Israel who makes all the subsidiary's decisions may cause it to be treated as an Israeli resident as well. A full analysis is in the guide for an Israeli investor in a foreign project company.

5Does an Israeli company need to register for VAT in Greece?

Yes, if it makes VAT-taxable transactions in Greece, and a subsidiary or branch in Greece receives a VAT number already on registration. An Israeli company without a permanent establishment that makes VAT-taxable transactions in Greece, for example a local sale of imported goods, needs to check its registration obligation. According to professional VAT guides, Greece has no registration threshold for foreign businesses, and a non-EU business must appoint a VAT fiscal representative, under a notarised power of attorney with an apostille and Greek translation. The representative usually bears joint liability for the VAT debt. The main exception is registration under the special scheme of the EU OSS system for distance sales to consumers.

The standard VAT rate in Greece is 24%, and there are reduced rates of 13% and 6%. Reporting goes through the myDATA system of the Greek tax authority (AADE), and in 2026 a B2B e-invoicing obligation was phased in. Details on tax are in the guide to tax in Greece.

6What are an employer's obligations in Greece?

To pay at least the minimum wage, 920 euros gross a month from 1 April 2026 under Ministerial Decision 8934/2026, to pay social security contributions and withhold income tax from salaries, and to comply with Greek employment law, which applies even when the employer is an Israeli company. These are the main points:

• Minimum wage: 920 euros gross a month from 1 April 2026, under Ministerial Decision 8934/2026, compared with 880 euros previously.
• Working hours: 40 hours a week, 8 hours a day in a five-day week. Overtime is limited, reported in advance in the ERGANI system and paid at a premium.
• Social security: 21.79% for the employer and 13.37% for the employee, up to a monthly ceiling of 7,761.94 euros from 2026. The employer also withholds income tax from the salary.
• Annual leave: 20 working days in a five-day week, rising by one day for each year of service up to 22, and more after long service. In addition, holiday pay and statutory Christmas and Easter bonuses are paid.
• Safety: under Law 3850/2010 every employer appoints a safety officer, and above 50 employees also an occupational physician, and prepares a written risk assessment.
• Equality: a prohibition on discrimination, and a profitable company with more than 50 employees must employ people with disabilities and from protected categories at a rate of 8%.

Dismissal must be in writing. An employee who claims that the dismissal is void must file a claim within three months, and a claim for severance within six months. There is special protection for groups such as pregnant women, a father in the six months after the birth and employee representatives. The data in the table is taken from Deloitte Legal's review of July 2024, and the current text should be checked before any dismissal.

7What is important to know about contracts in Greece?

A contract between companies can be written in English and choose a foreign law, but in proceedings before a Greek court an official Greek translation will be required, and mandatory provisions of Greek law apply in any event. The main points:

• Good faith in negotiations: under Articles 197 and 198 of the Civil Code, the parties must act in good faith even before signing, and a party that caused damage through bad faith is liable to compensate even if the contract was not signed.
• Commercial agents: relationships with a commercial agent are governed by Presidential Decree 219/1991, mainly as to notice periods on termination and goodwill indemnity for customers. The agency agreement should be drafted accordingly.
• Governing law: a Greek court generally respects a choice of foreign law in a commercial contract under the Rome I Regulation, subject to the mandatory provisions of Greek law.
• Language: a contract between companies can be written in English, but in proceedings before a Greek court an official Greek translation will be required. It is therefore worth considering a bilingual text for key contracts.
• Dispute resolution: from 1 March 2027 a preliminary mediation obligation applies in Greece to a large proportion of commercial claims, and a valid mediation clause in the contract fulfils it.

8Is a licence needed for activity in Greece?

Ordinary commercial activity does not require a special licence beyond registration with GEMI and the appropriate activity codes (ΚΑΔ). Regulated activity, such as financial services, tourism and hospitality, food, construction and energy, requires permits from the competent authority in each sector, which should be checked before entering the market. Under Law 1892/1990, entities and individuals from outside the EU and EFTA may not acquire properties in border areas, or shares in a company holding such properties, without approval. See the guide to border areas.

Greece has no general foreign investment approval regime, and according to Deloitte it has no currency controls. A merger between companies requires notification to the Competition Commission when the combined worldwide turnover is at least 150 million euros, and at least two of the companies each have turnover in Greece of more than 15 million euros.

9How is money transferred between Israel and Greece?

By an ordinary bank transfer, without special approval: the capital controls in Greece were lifted in September 2019, and there are no currency controls. In practice, Greek banks carry out in-depth know-your-customer checks on foreign-owned companies, and will ask for documents on the ownership structure, the source of funds and the activity. It is worth preparing an organised document file in advance; see the guide to the AFM and a bank account in Greece and the explanation of know-your-customer checks.

Transferring profits from a branch to the parent company is not subject to withholding tax in Greece, and a dividend from a subsidiary is subject to 5% withholding. In Israel, the Israeli company reports the foreign income and receives a credit for the tax paid in Greece under the rules. The structure for taking profits out is planned with an Israeli accountant.

10What is the annual compliance calendar for a subsidiary in Greece?

The recurring obligations are the GEMI fee in the first quarter (according to the GEMI website, as of November 2026: 100 euros for an IKE and 320 euros for an AE), the corporate tax return by the end of the sixth month after the end of the tax year, and the approval and filing of the financial statements. The details:

11What is the recommended order for entering the Greek market?

First define the activity and check whether it creates a permanent establishment, and only then choose a structure, register and hire staff. The order:

1. Define the planned activity in Greece: sales, services, a project, employees or assets.
2. Check whether the activity creates a permanent establishment under Greek law and under the treaty.
3. Choose a structure: direct activity, branch, subsidiary or Law 89 office.
4. Obtain Greek tax numbers, and appoint a tax representative or VAT representative as needed.
5. Register the entity with GEMI and open a bank account.
6. Recruit employees under Greek employment law, with registration in ERGANI and EFKA.
7. Draft contracts with customers, suppliers and agents, including a dispute resolution clause and governing law.
8. Set an annual compliance calendar and coordinate reporting in Israel.

This guide is general information, and every market entry needs a specific review of the structure, tax and licensing according to the activity.

More on doing business in Greece: Setting up a company in Greece · Corporate tax and transferring profits to Israel from Greece · Commercial disputes and litigation in Greece · Comparison of 8 countries · All guides for companies and businesses

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