Tax Flash: Law 5313/2026: Tax treatment of carried interest – Alternative investment funds & third-country investment funds

Articles 96-98 of Law 5313/2026 introduce legislative provisions that significantly broaden the framework for the taxation of carried interest and enhance Greece's attractiveness as a center for the provision of services in the field of alternative investments.

Specifically, they regulate:

  • The extension of the favorable taxation of carried interest to employees of Greek companies providing services to AIF managers (EU and third countries).
  • The introduction of a preferential tax rate of 5% (instead of 15%) under specific cumulative conditions.
  • The recognition of the deductibility of carried interest as a business expense.
  • The establishment of an explicit provision that no place of effective management and no permanent establishment is created in Greece for EU/third-country AIFs, as well as for their managers.

Download the flash to learn all the details.

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Stavroula Marousaki

Stavroula Marousaki

Partner, Tax, PwC Greece

Costas  Kallideris

Costas Kallideris

Director, Tax, PwC Greece

Dimitrios Arampatzis

Dimitrios Arampatzis

Director, Tax, Transfer Pricing, PwC Greece

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