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EXECUTIVE SUMMARY

After nearly ten years of austerity measures and reforms under three economic adjustment programs, Greece made significant progress in 2019 in its return to economic normalcy.  The New Democracy party won elections in July 2019 on a mandate to continue to reform and streamline the economy as well as attract foreign direct investment.  Growth reached an estimated 1.9% in 2019.  The government exceeded its 2019 primary surplus target of €4.4 billion, recording a surplus of €4.96 billion.  Major challenges remain, however, considering the economic disruption expected from lockdown measures imposed in response to COVID-19.  At the end of 2019, Greece’s public debt was €342.9 billion, or more than 176% of GDP.  Unemployment decreased slightly in 2019, reaching 16.4% by January 2020.  Both of these numbers are expected to rise in the aftermath of COVID-19.

Greece maintains a liquidity buffer, estimated at €26 billion, thanks to the addition of a final €15 billion loan tranche disbursed by the European Stability Mechanism (ESM).  So far untouched, the buffer should be sufficient to cover the country’s financing needs until at least the end of 2022, and the country’s leadership maintains its intention to reserve the ESM tranche solely for sovereign debt interest payments.  Capital controls were completely lifted in September 2019.  Greece remains subject to enhanced supervision by Eurozone creditors, and the government met its goal of a primary budget surplus of 3.5% of GDP in 2019.  Greece had committed to meet the annual primary budget surplus target of 3.5% of GDP through 2022 and 2.2% afterwards, although its Eurozone creditors have suspended the surplus requirement this year due to COVID-19.

In previous years, concerns over economic and political stability within Greece essentially froze most new investment and caused some existing investors to scale down or withdraw entirely from the Greek market, but this is no longer the case.  Success in the privatization of Greece’s fourteen regional airports, investment in the tourism sector, and the construction of the Trans-Adriatic Pipeline demonstrated the opportunities that have existed in Greece even during the height of the economic crisis.  Greek travel and tourism receipts jumped 12.8% in 2019 to a record €18.5 billion with a 4.1% increase in tourist arrivals in 2019.  Prices for residential properties rose 7.2%, a huge jump from 1.2% in 2018, and individual FDI in real estate has tripled from €414 million in 2017 to €1.45 billion in 2019.  Chinese investors continue to eye Greece for real estate purchases, with inquiries from Chinese buyers increasing by 109% in the first quarter of 2020 as compared to the first quarter of 2019, with much of the interest attributed to Greece’s attractive Golden Visa program.

Greece’s return to economic growth has generated new investor interest in the country.  In January 2019, Greece successfully raised €2.5 billion in a five-year bond sale at a yield of 3.6% and €487 million in 13-week treasury bills in October 2019 with a yield of –0.02%, the first time Greece has ever had a negative yield.  In January 2020, Greece raised another €2.5 billion in a fifteen-year bond sale at a yield of 1.9%, demonstrating the country’s strong return to the capital markets.

In January 2020, Fitch ratings agency upgraded Greece’s credit rating to BB, although it lowered its outlook from ‘positive’ to ‘stable’ in April 2020 due to the financial impact of COVID-19.  Standard & Poor’s raised Greece’s credit rating from BB- to B+ in October 2019, although it also downgraded its outlook to ‘stable’ in April 2020.  For the first time, the European Central Bank (ECB) included Greek government bonds in its quantitative easing program, with €12 billion worth of Greek government debt to be purchased under the ECB’s €750 billion Pandemic Emergency Purchase Program in 2020.

Although Greece has seen positive developments in the past few years, investors worry about where Greece will be once COVID-19 subsides.  The Greek Government has been given strong marks for its initial response in limiting the spread of the pandemic and has implemented several innovative digital reforms to its economy during COVID-19.  The extent of the impact is yet to come, but the Bank of Greece, EU, IMF, and others have predicted a contraction of 4-15% in 2020.  The tourism sector in particular, which comprises almost a quarter of the economy, is likely to take a hit with predictions of a 50-70% loss in tourism revenue.  Estimates of unemployment hover around 20% or higher.  As 2020 continues, the resiliency of the Greek economy will be tested, with uncertain impacts on the investment climate.

Table 1: Key Metrics and Rankings 
Measure Year Index/Rank Website Address
TI Corruption Perceptions Index 2019 60 of 180 https://www.transparency.org/country/GRC
World Bank’s Doing Business Report 2020 79 of 190 https://www.doingbusiness.org/
en/data/exploreeconomies/greece
Global Innovation Index 2019 41 of 129 https://www.globalinnovationindex.org/
analysis-indicator
U.S. FDI in partner country ($M USD, historical stock positions) 2018 $1.4 billion https://apps.bea.gov/international/
factsheet/factsheet.cfm?Area=310
World Bank GNI per capita 2018 $19,770 http://data.worldbank.org/
indicator/NY.GNP.PCAP.CD

1. Openness To, and Restrictions Upon, Foreign Investment

Policies Towards Foreign Direct Investment

The Greek government continues to state its desire to increase foreign investment, though the country remains a challenging climate for investment, both foreign and domestic, and will likely remain so in light of the COVID-19 crisis.  However, Greece completed its EU bailout program in 2018, allowing it to borrow once again at market rates, reflected in a rising economic sentiment since 2017.

There are no laws or practices known to Post that discriminate against foreign investors.

The General Secretariat for Strategic and Private Investments streamlines the licensing procedure for strategic investments, aiming to make the process easier and more attractive to investors.

Greece has adopted the following EU definitions regarding micro, small, and medium size enterprises:

  • Micro Enterprises:  Fewer than 10 employees and an annual turnover or balance sheet below €2 million.
  • Small Enterprises:  Fewer than 50 employees and an annual turnover or balance sheet below €10 million.
  • Medium-Sized Enterprises:  Fewer than 250 employees and annual turnover below €50 million or balance sheet below €43 million.

Numerous structural reforms, both undertaken as part of the country’s 2015-2018 international bailout program, as well as a part of New Democracy’s efforts to reduce bureaucracy and red tape, aim to welcome and facilitate foreign investment, and the government has publicly messaged its dedication to attracting foreign investment.  The Trans Adriatic Pipeline (TAP) is one example of the government’s commitment in this area.  In November 2015, the Greek government and TAP investors agreed on measures and began construction on the largest investment project since the start of the financial crisis, with the pipeline set to begin operations in late 2020.  Nevertheless, many structural reforms have created greater challenges to investors and established businesses in Greece.  The country has undergone one of the most significant fiscal consolidations in modern history, with broad and deep cuts to public expenditures and significant increases in labor and social security tax rates, which have offset improved labor market competitiveness achieved through significant wage devaluation.  While there has been notable progress, corruption and burdensome bureaucracy continue to create barriers to market entry for new firms, permitting incumbents to maintain oligopolies in different sectors, and creating scope for arbitrary decisions and rent seeking by public servants.

Limits on Foreign Control and Right to Private Ownership and Establishment

As a member of the EU and the European Monetary Union (the “Eurozone”), Greece is required to meet EU and Eurozone investment regulations.  Foreign and domestic private entities have the legal right to establish and own businesses in Greece; however, the country places restrictions on foreign equity ownership higher than those imposed on average in the other 17 high-income OECD economies, such as equity restrictions on airport operations and limits on foreign ownership in electricity and media.  The government has undertaken EU-mandated reforms in its energy sector, opening much of it to foreign equity ownership.  Restrictions exist on land purchases in border regions and on certain islands because of national security considerations.  Foreign investors can buy or sell shares on the Athens Stock Exchange on the same basis as local investors.  Greece does not maintain an investment screening mechanism.

Other Investment Policy Reviews

In March 2018, the OECD published an economic survey describing the state of the economy and addressing foreign direct investment concerns.  The government has sought the OECD’s counsel and technical assistance to carry out select reforms from the recommendations and develop additional reforms in line with the government’s emphasis on the social welfare state.  Greece also underwent an OECD Development Co-operation Peer Review in February 2019, where Greece’s positive support to asylum seekers was noted.

Business Facilitation

“Enterprise Greece” is the official investment promotion agency of the Greek state.  Under the supervision of the Ministry of Foreign Affairs, Enterprise Greece is responsible for promoting investment in Greece and exports from Greece, and with making Greece more attractive as an international business partner.  Enterprise Greece provides the full spectrum of services related to international business relationships and domestic business development for the international market, including an Investor Ombudsman program for investment projects exceeding €2 million.  The Ombudsman is available to assist with specific bureaucratic obstacles, delays, disputes, or other difficulties that impede an investment project.  Enterprise Greece is now housed within the Economic Diplomacy Department of the Ministry of Foreign Affairs.

In 2020, Greece eased processes for starting a business resulting in reduced time to register a company and removing the requirement to obtain a tax clearance.  Accessing industrial land in Greece is relatively quick, with only three weeks required to lease land from the government.  Private land can be leased in 15 days.

The fast track law, passed in December 2010, aimed to simplify the licensing and approval process for “strategic” investments, i.e. large-scale investments that will have a significant impact on the national economy.  In 2013, Greece’s parliament passed Investment Law 4146/2013 to simplify the regulatory system and stimulate investment.  This law provides additional incentives, beyond those in the fast track law, available to domestic and foreign investors, dependent on the sector and the location of the investment.

Greece’s business registration entity GEMI (General Commercial Register) has the basic responsibility for digitizing and automating the registration and monitoring procedures of commercial enterprises.  More information about GEMI can be found at http://www.businessportal.gr/home/index_en  The online business registration process is relatively clear, and although foreign companies can use it, the registration steps are currently available only in Greek.  In general, a company must register with the business chamber, tax registry, social security, and local municipality.  Business creation without a notary can be done for specific cases (small/personal businesses, etc.).  For the establishment of larger companies, a notary is mandatory.  Establishing a limited liability company takes approximately four days with three procedures involved, including registering the business, making a company seal, and registering with the Unified Social Security Institution.

Outward Investment

The Greek government does not have any known outward investment incentive programs.  Capital controls were eliminated in September 2019.

Enterprise Greece supports the international expansion of Greek companies.  While no incentives are offered, Enterprise Greece has been supportive of Greek companies attending the U.S. Government’s Annual SelectUSA Investment Summit, which promotes investment in the United States, and similar industry trade events internationally.

2. Bilateral Investment Agreements and Taxation Treaties

Greece and the United States signed the 1954 Treaty of Friendship, Commerce, and Navigation, which provides certain investment protection, such as acquisition and protection of property and impairment of legally acquired rights or interests.

As an EU member state, Greece does not have a bilateral Free Trade Agreement (FTA) with the United States but is a party to all U.S.-EU agreements.  Greece has Bilateral Investment Treaties (BITs) with:

1 Albania
2 Algeria
3 Argentina*
4 Armenia
5 Azerbaijan
6 Bosnia and Herzegovina
7 Bulgaria
8 Chile
9 China
10 Congo*
11 Croatia
12 Cuba
13 Cyprus
14 Czech Republic
15 Egypt
16 Estonia
17 Georgia
18 Germany
19 Hungary
20 Iran
21 Jordan
22 Kazakhstan*
23 Korea
24 Kuwait*
25 Latvia
26 Lebanon
27 Lithuania
28 Mexico
29 Moldova
30 Montenegro
31 Morocco
32 Poland
33 Romania
34 Russian Federation
35 Serbia
36 Slovakia
37 Slovenia
38 South Africa
39 Syria
40 Tunisia
41 Turkey
42 Ukraine
43 United Arab Emirates
44 Uzbekistan
45 Viet Nam

*Signed, but not in force

Greece and the United States share a Double Taxation Treaty.  Greece is a signatory country to the United States’ Foreign Account Tax Compliance Act (FATCA), aimed at addressing tax evasion by U.S. citizens or permanent residents with foreign bank accounts.  For more information, visit the FATCA website: https://www.irs.gov/Businesses/Corporations/Foreign-Account-Tax-Compliance-Act-FATCA .

3. Legal Regime

Transparency of the Regulatory System 

As an EU member, Greece is required to have transparent policies and laws for fostering competition.  However, foreign companies generally consider the complexity of government regulations and procedures and their inconsistent implementation to be a significant impediment to investing and operating in Greece.  Occasionally, foreign companies report cases where there are multiple laws governing the same issue, resulting in confusion over which law is applicable.  Under its bailout programs, the Greek government committed to widespread reforms to simplify the legal framework for investment, including eliminating purely bureaucratic obstacles, redundancies, and undue regulations.

Proposed laws and regulations are published in draft form for public comment before Parliament takes up consideration of the legislation.  The laws in force are accessible on a unified website managed by the government and printed in an official gazette.  Greece introduced International Financial Reporting Standards for listed companies in 2005 in accordance with EU directives.  These rules improved the transparency and accountability of publicly traded companies.

While foreign firms are not subject to discrimination in taxation,  numerous changes to tax laws and regulations since the beginning of the economic crisis have injected uncertainty into Greece’s tax regime.  As part of Greece’s August 2015 bailout agreement, the government converted the Ministry of Finance’s Directorate-General for Public Revenue into a fully independent tax agency effective January 2017, with a broad mandate to increase collection and develop further reforms to the tax code aimed at reducing evasion and increasing the coverage of the Greek tax regime.

International Regulatory Considerations

Citizens of other EU member state countries may work freely in Greece.  Citizens of non-EU countries may work in Greece after receiving residence and work permits.  There are no discriminatory or preferential export/import policies affecting foreign investors, as EU regulations govern import and export policy, and increasingly, many other aspects of investment policy in Greece.

Greece has been a World Trade Organization (WTO) member since January 1, 1995, and a member of the General Agreement on Tariffs and Trade (GATT) since March 1, 1950.  Greece complies with WTO Trade-Related Investment Measures (TRIMs) requirements.  There are no performance requirements for establishing, maintaining, or expanding an investment.  Performance requirements may come into play, however, when an investor wants to take advantage of certain investment incentives offered by the government.  Greece has not enacted measures that are inconsistent with TRIMs requirements, and the Embassy is not aware of any measures alleged to violate Greece’s WTO TRIMs obligations.  Trade policy falls within the competence and jurisdiction of the European Commission Directorate General for Trade and is generally not subject to regulation by member state national authorities.

Legal System and Judicial Independence

Although Greece has an independent judiciary, the court system is an extremely time-consuming and unwieldy means for enforcing property and contractual rights.  According to the “Enforcing Contracts Indicator” of the World Bank’s ‘Doing Business 2020” Index, Greece ranks 146 among 190 countries in terms of the speed of delivery of justice, requiring 1,711 days (more than four years) on average to resolve a dispute, compared to the OECD high-income countries’ average of 590 days.

The government has committed, as part of its three bailout packages, to reforms intended to expedite the processing of commercial cases through the court system.  In July 2015, the government adopted significant reforms to the Code of Civil Procedure (Law 4335/2015).  These reforms aimed to accelerate judicial proceedings in support of contract enforcement and investment climate stability, entering into force in January 2016.  Foreign companies report, however, that Greek courts do not consistently provide fast and effective recourse.  Problems with judicial corruption reportedly still exist.  Commercial and contractual laws accord with international norms, and the judicial system remains independent of the executive branch.

Laws and Regulations on Foreign Direct Investment

In 2019, two new laws were introduced aiming to boost investments in Greece by third-country nationals:

-Law 4605/2019 expands the types of investments that qualify an individual for a residence permit, allowing investments in intangible assets.  In particular, capital contribution of at least €400,000 in a real estate investment company, in a company registered in Greece, in a purchase of state bonds, corporate bonds, or shares, in a venture capital investment company, or in mutual funds, allows the investor and his or her family members a five-year residency permit in Greece.

-Law 4608/2019 for strategic investments was approved in April 2019, creating a favorable investment climate by providing various privileges to investors such as tax exemptions and fast track licensing.

Investments in Greece operate under two main laws:  the new Investment Law (4399/2016) that addresses small-scale investments and Law 4146/2013 that addresses strategic investments.  In particular:

– Law 4399/2016, entitled “Statutory framework to the establishment of Private Investments Aid Schemes for the regional and economic development of the country” was passed in June 2016.  Its key objectives include the creation of new jobs, the reindustrialization of the country, and the attraction of FDI.  The law provides aids (as incentives) for companies that invest from €50,000 (Social Cooperative Companies) up to €500,000 (large sized companies) as well as tax breaks.  The Greek government provides funds to cover part of the eligible expenses of the investment plan; the amount of the subsidy is determined based on the region and the business size.  Qualified companies are exempt from paying income tax on their pre-tax profits for all their activities.  There is a fixed corporate income tax rate and fast licensing procedures.  Eligible economic activities are manufacturing, shipbuilding, transportation/infrastructure, tourism, and energy.  More about this law can be found here: https://www.enterprisegreece.gov.gr/files/pdf/madrid2019/2-Investment-Incentives-Law.pdf .

– Law 4146/2013, entitled the “Creation of a Business-Friendly Environment for Strategic and Private Investments” is the other primary investment incentive law currently in force.  The law aims to modernize and improve the institutional framework for private investments, raise liquidity, accelerate investment procedures, and increase transparency.  It seeks to provide an efficient institutional framework for all investors and speed the approval processes for pending and approved investment projects.  The law created a general directorate for private investments within the Ministry of Development and Investment and reduced the value of investments needed to be considered strategic.  The law also provides tax exemptions and incentives to investors and allows foreign nationals from non-EU countries who buy property in Greece worth over €250,000 ($285,000) to obtain five-year renewable residence permits for themselves and their families.  In March 2019, the Greek government brought a bill to parliament to expand eligibility criteria of the existing program.

– Law 3908/2011, which provides incentives in the form of tax relief, grants, and allowances on investments, is gradually being phased out by Law 4146 (above).

– Law 3919/2011 aims to liberalize more than 150 currently regulated or closed-shop professions.

– Law 3982/2011 reduced the complexity of the licensing system for manufacturing activities and technical professions and modernized certain qualification and certification requirements to lower barriers to entry.

– Law 4014/2011 simplified the environmental licensing process.

– Law 3894/2010 (also known as fast track) allows Enterprise Greece to expedite licensing procedures for qualifying investments in the following sectors: industry, energy, tourism, transportation, telecommunications, health services, waste management, or high-end technology/innovation.  To qualify, investments must meet one of the following conditions:

  • exceed €100 million;
  • exceed €15 million in the industrial sector, operating in industrial zones;
  • exceed €40 million and concurrently create at least 120 new jobs; or
  • create 150 new jobs, regardless of the monetary value of the investment.

More about fast track licensing of strategic investments can be found online at https://www.enterprisegreece.gov.gr/en/invest-in-greece/strategic-investments 

Other investment laws include:

In October 2019, Parliament passed an economic development bill, Law 4635/2019, aimed at boosting economic recovery in the post-bailout era which entered into force in January 2020.  The bill, called “Invest in Greece and other provisions,” simplifies processes for investors regarding environmental and urban planning regulations, speeding up bureaucratic processes.  The bill also introduces changes to labor union alterations to encourage job creation and reforms the functioning of the General Commercial Registry.

– Law 3389/2005 introduced the use of public-private partnerships (PPP).  This law aimed to facilitate PPPs in the service and construction sectors by creating a market-friendly regulatory environment.

–  Law 3426/2005 completed Greece’s harmonization with EU Directive 2003/54/EC and provided for the gradual deregulation of the electricity market.  Law 3175/2003 harmonized Greek legislation with the requirements of EU Directive 2003/54/EC on common rules for the internal electricity market.  Law 2773/99 initially opened 34% of the Greek energy market, in compliance with EU Directive 96/92 concerning regulation of the internal electricity market.

– Law 3427/2005, which amended Law 89/67, provides special tax treatment for offshore operations of foreign companies established in Greece.  Special tax treatment is offered only to operations in countries that comply with OECD tax standards.

– Law 2364/95 and supporting amendments govern investment in the natural gas market in Greece.

– Law 2289/95, which amended Law 468/76, allows private (both foreign and domestic) participation in oil exploration and development.

– Law 2246/94 and supporting amendments opened Greece’s telecommunications market to foreign investment.

– Legislative Decree 2687 of 1953, in conjunction with Article 112 of the Constitution, gives approved foreign “productive investments” (primarily manufacturing and tourism enterprises) property rights, preferential tax treatment, and work permits for foreign managerial and technical staff.  The Decree also provides a constitutional guarantee against unilateral changes in the terms of a foreign investor’s agreement with the government, but the guarantee does not cover changes in the tax regime.

Competition and Anti-Trust Laws

Under Articles 101-109 of the Treaty on the Functioning of the EU, the European Commission (EC), together with member state national competition authorities, directly enforces EU competition rules.  The EC Directorate-General for Competition carries out this mandate in member states, including Greece.  Greece’s competition policy authority rests with the Hellenic Competition Commission, in consultation with the Ministry of Economy.  The Hellenic Competition Commission protects the proper functioning of the market and ensures the enforcement of the rules on competition.  It acts as an independent authority and has administrative and financial autonomy.

Expropriation and Compensation

Private property may be expropriated for public purposes, but the law requires this be done in a nondiscriminatory manner and with prompt, adequate, and effective compensation.  Due process and transparency are mandatory, and investors and lenders receive compensation in accordance with international norms.  There have been no expropriation actions involving the real property of foreign investors in recent history, although legal proceedings over expropriation claims initiated, in one instance, over a decade ago, continue to work through the judicial system.

Dispute Settlement

ICSID Convention and New York Convention

Greece is a member of both the International Centre for the Settlement of Investment Disputes (ICSID) and the Recognition and Enforcement of Foreign Arbitral Awards (1958 New York convention).

Investor-State Dispute Settlement

Greece accepts binding international arbitration of investment disputes between foreign investors and the Greek government, and foreign firms have found satisfaction through arbitration.  International arbitration and European Court of Justice judgments supersede local court decisions.  The judicial system provides for civil court arbitration proceedings for investment and trade disputes.  Although an investment agreement could be made subject to a foreign legal jurisdiction, this is not common, particularly if one of the contracting parties is the Greek government.  Foreign court judgments are accepted and enforced, albeit slowly, by the local courts.

In an effort to create a more investor-friendly environment, the government established in 2017 an Investor’s Ombudsman service.  The Ombudsman is authorized to mediate disputes that arise between investors and the government during the licensing procedure.  Investors can employ the Ombudsman, housed within the investment promotiona agency, Enterprise Greece, with projects exceeding €2 million in value.  More info on the Ombudsman service can be found here: https://www.enterprisegreece.gov.gr/en/invest-in-greece/ombudsman 

International Commercial Arbitration and Foreign Courts

The two main alternative dispute resolution mechanisms in Greece are domestic and international commercial arbitration or mediation.  Domestic arbitration is governed under the Code of Civil Procedure (CCP), and mediation is governed under The Mediation Act, Law 3898/2010, modeled after the UNCITRAL Model Law.  Greece recognizes foreign judgments under articles 323 and 780 of the CCP and articles 15-21 of Law 3858/2010.

Bankruptcy Regulations

Bankruptcy laws in Greece meet international norms.  Under Greek bankruptcy law 3588/2007, private creditors receive compensation after claims from the government and insurance funds have been satisfied.  Monetary judgments are usually made in euros unless explicitly stipulated otherwise.  Greece has a reliable system of recording security interests in property.  According to the World Bank’s 2020 Doing Business Index, resolving insolvency in Greece takes 3.5 years on average and costs nine percent of the debtor’s estate, with the most likely outcome that the company will be sold piecemeal.  Recovery rate is 32 cents on the dollar.  Greece ranks 72 of 190 economies surveyed for ease of resolving insolvency.

4. Industrial Policies

Investment Incentives

Investment incentives are available on an equal basis for both foreign and domestic investors in productive enterprises.  The investment laws in Greece aim to increase liquidity, accelerate investment processes, and ensure transparency.  They provide an efficient institutional framework for all investors and speed the approval process for pending investment projects.  The basic investment incentives Law 4146/2013, “Creation of a Development Friendly Environment for Strategic and Private Investments,” aims to modernize and improve the institutional and legal framework to attract private investment.  Separately, Law 3908/2011 (which replaced Law 3299/2004) provides incentives in the form of tax relief, cash grants, leasing subsidies, and soft loans on qualifying investments in all economic sectors with some exceptions.

In evaluating applications for tax and other financial incentives for investment, Greek authorities consider several criteria, including the viability of the planned investment; the expected impact on the economy and regional development (job creation, export orientation, local content use, energy conservation, environmental protection); the use of innovative technology; and the creditworthiness and capacity of the investor.  Progress assessments are conducted on projects receiving incentives, and companies that fail to implement projects as planned may be forced to give up incentives initially granted to them.  All information transmitted to the government for the approval process is to be treated confidentially by law.

Investment categories are:

  1. General Entrepreneurship
  2. Regional Cohesion
  3. Technological development
  4. Youth Entrepreneurship (18-40 years old)
  5. Large Investment Plans (above €50 million)
  6. Integrated, Multi-Annual Business Plans
  7. Partnership & Networking

The entire application and evaluation process shall not exceed six months (more information can be found at https://www.ependyseis.gr ).

Foreign Trade Zones/Free Ports/Trade Facilitation

Greece has four free-trade zones, located at the Piraeus, Thessaloniki, Heraklion, and Platigiali Astakos Etoloakarnias port areas.  Greek and foreign-owned firms enjoy the same advantages in these zones.  Goods of foreign origin may be brought into these zones without payment of customs duties or other taxes and may remain free of all duties and taxes if subsequently transshipped or re-exported.  Similarly, documents pertaining to the receipt, storage, or transfer of goods within the zones are free from stamp taxes.  Handling operations are carried out according to EU regulations 2504/1988 and 2562/1990.  Transit goods may be held in the zones free of bond.  These zones also may be used for repackaging, sorting, and re-labeling operations.  Assembly and manufacture of goods are carried out on a small scale in the Thessaloniki Free Zone.  Storage time is unlimited, as long as warehouse rents are paid every six months.

Performance and Data Localization Requirements

The Greek government does not follow a policy of forced localization or mandate local employment, designed to require foreign investors to use domestic content in goods or technology, with the exception of economic development requirements in many defense contracts (see Research and Development, below).  Some foreign investors partner with local companies or to hire local staff/experts, however, as a way to facilitate their entry into the market.  In 2019, the government enacted a new amendment to the Greek tourism legislation, which obligates tour operators from third countries who do not own a travel agency in Greece to collaborate with a local travel agency established in the country to be able to conduct its business locally.  The government is not taking steps to force foreign investors to keep a specific amount of the data they collect and store within Greek national borders.

Research and Development

Offset agreements, co-production, and technology transfers are commonplace in Greece’s procurement of defense items.  Although the most recent Greek defense procurement law eliminated offset requirements, there are some remaining ongoing active offset contracts, as well as expired offset contracts with U.S. firms that are potentially subject to non-performance penalties.  Defense procurements are still subject to economic development requirements, which are, in effect, similar to offsets.  In 2014, the government committed to resolving offset contract disputes in a way that would satisfy both parties and avoid the imposition of penalties or fines.

In general, U.S. and other foreign firms may participate in government-financed and/or subsidized research and development programs.  Foreign investors do not face discriminatory or other formal inhibiting requirements.  However, many potential and actual foreign investors assert the complexity of Greek regulations, the need to deal with many layers of bureaucracy and the involvement of multiple government agencies all discourage investment.

5. Protection of Property Rights

Real Property

Greek laws extend the protection of property rights to both foreign and Greek nationals, and the legal system protects and facilitates acquisition and disposition of all property rights.

Multiple layers of authority in Greece are involved in the issuance or approval of land use and zoning permits, creating disincentives to real property investment.  Secured interests in property are movable and real, recognized and enforced.  The concept of mortgage does exist in the market and can be recorded through the banks.  The government is working to create a comprehensive electronic land registry which is expected to increase the transparency of real estate management.  However, the land registry is behind schedule and is not expected to be completed before 2022.  Greece ranks 156 out of 190 countries for Ease of Registering Property in the World Bank’s Doing Business 2020 Index.

Foreign nationals can acquire real estate property in Greece, though they first need to be issued a tax authentication number.  However, to acquire sensitive border areas, foreign nationals must first require a license from the Greek state (Law 3978/2011).  In another effort to boost investment, the government passed Law 4146/2013, which allows foreign nationals who buy property in Greece worth over €250,000 ($285,000) to obtain a five-year residence permit for themselves and their families.  The “Golden Visa” program has been extended to buyers of various types of Greek securities, including stocks, bonds, and bank accounts, with a value of at least €400,000.  The permit can be extended indefinitely in five-year increments and allows travel to other EU and Schengen countries without a visa.

Intellectual Property Rights

In April 2020, Greece was removed from the U.S. Trade Representative (USTR) Special 301 Report Watch List due to progress in addressing concerns regarding intellectual property rights (IPR) protection and enforcement.  In December 2019, Greece took clear steps to address the long-standing concern of widespread public sector use of unlicensed software by allocating over €39 million for the purchase of software licenses.  In addition, the Committee for Notification of Copyright and Related Rights Infringement on the Internet has been taking steps to address enforcement in the online environment, and Greece introduced a new law imposing fines for possessing counterfeit goods.  In 2019, the Ministry of Culture developed draft legislation which would allow for the dynamic blocking of infringing domains, which would improve of the enforcement of IPR.  The bill is expected to be voted on in 2020.

Greece tracks seizures of counterfeit goods; however, the Ministry of Finance, Coast Guard, and Customs Service all track their data separately.  In 2019, the Hellenic Coast Guard arrested 143 people during 110 cases, seizing over 9 million counterfeit cigarettes, 10 vehicles, and over 1,300 pounds of tobacco, which combines for €1.8 million in attempted tax evasion.  The Ministry of Finance’s Economic and Financial Crimes Unit (SDOE) conducts investigations and seizures of counterfeit goods.  In 2019, the SDOE seized almost 600,000 counterfeit and pirated products, down from 1.1 million in 2018.  The Hellenic Customs Service also conducts inspections at exit and entry points into the EU; in 2019 they seized over 20 million counterfeit goods, the majority of which were cigarettes.  Violators can be fined for their actions, and Law 3982/2022 provides police ex officio authority to confiscate and destroy counterfeit goods.

Greece is noted in the 2019 Notorious Markets List insofar that ISPs in country were recently ordered to block a number of infringing sites.

Greece is a member of the World Intellectual Property Organization (WIPO) and is party to the Berne Convention, the Paris Convention, the Patent Cooperation Treaty (PCT), the WIPO Copyright Treaty, and the WIPO Performances and Phonograms Treaty, among others.  Greece is a member of the European Patent Convention and, as a member of the EU, has harmonized its IP legislation with EU rules and regulations.  The World Trade Organization (WTO) Agreement on Trade-Related Aspects of Intellectual Property Rights (TRIPS) was incorporated into Greek law on February 28, 1995 (Law 2290/1995).  Greece’s legal framework for copyright protection is found in Law 2121/1993 and Law 2328/1995.

For additional information about treaty obligations and points of contact at local IP offices, please see WIPO’s country profiles at http://www.wipo.int/directory/en/ .
Resources for Rights Holders 

Embassy Point of Contact:

U.S. Embassy Athens
Economic Section
91 Vas. Sofias Avenue, Athens, Greece 10160
Phone:  +30-210-721-2951
Athens-ECON@state.gov

A list of local attorneys is available at gr.usembassy.gov/u-s-citizen-services/attorneys/

American-Hellenic Chamber of Commerce
109-111 Messoghion Avenue, Politia Business Center
Athens, Greece 11526
Phone: +30-210-699-3559, Fax: +30-210-698-5686
Email: info@amcham.gr
Web Site: www.amcham.gr 

6. Financial Sector

Capital Markets and Portfolio Investment

Following EU regulations, Greece is open to foreign portfolio investment.  Law 3371/2005 sets an effective legal framework to encourage and facilitate portfolio investment.  Law 3283/2004 incorporates the European Council’s Directive 2001/107, setting the legal framework for the operation of mutual funds.  The Bank of Greece complies with its IMF Article VIII obligations and does not generally impose restrictions on payments.  Transfers for current international transactions are allowed but are subject to specific conditions for approval.  The lack of liquidity in the Athens Stock Exchange along with the challenging economic environment have hindered the allocation of credit but is accessible to foreign investors on the local market, who also have access to a variety of credit instruments.

There are a limited number of cross-shareholding arrangements among Greek businesses.  To date, the objective of such arrangements has not been to restrict foreign investment.  The same applies to hostile takeovers, a practice which has been recently introduced in the Greek market.  The government actively encourages foreign portfolio investment.

Greece has a reasonably efficient capital market that offers the private sector a wide variety of credit instruments.  Credit is allocated on market terms prevailing in the Eurozone and credit is equally accessible by Greek and foreign investors.  An independent regulatory body, the Hellenic Capital Market Commission, supervises brokerage firms, investment firms, mutual fund management companies, portfolio investment companies, real estate investment trusts, financial intermediation firms, clearing houses and their administrators (e.g. the Athens Stock Exchange), and investor indemnity and transaction security schemes (e.g. the Common Guarantee Fund and the Supplementary Fund), and also encourages and facilitates portfolio investments.

Owner-registered bonds and shares are traded on the Athens Stock Exchange (ASE).  It is mandatory in Greece for the shares of banking, insurance, and public utility companies to be registered.  Greek corporations listed on the ASE that are also state contractors are required to have all their shares registered.

Money and Banking System

Greece’s banking system is not likely to be considered “healthy” and able to allocate funding to domestic firms that need it the most until its major banks adequately deal with the large amounts of non-performing loans (NPLs) on their balance sheets.

Greece’s banking system, despite three recapitalizations as part of the August 2015 ESM agreement, remains saddled with the largest ratio of non-performing loans in the EU, which constrains the domestic financial sector’s ability to finance the national economy.  As a result, businesses, particularly small and medium enterprises, still struggle to obtain domestic financing to support operations due to inflated risk premiums in the sector.  To tackle the issue, and as a requirement of the agreement with the ESM, Greece has established a secondary market for its non-performing loans (NPLs).  According to the Bank of Greece, Greek banks managed to bring down the total volume of NPLs from a peak of €107.2 billion in 2016 to roughly €70 billion by the end of 2019.  In addition to sales of securitized loan packages, the banks have exploited other ways to manage bad loans.

In November 2015, following an Asset Quality Review and Stress Test conducted by the ECB as a requirement of the new ESM agreement, a third recapitalization of Greece’s four systemic banks (National Bank of Greece, Piraeus Bank, Alpha Bank, and Eurobank) took place.  The recapitalization concluded with the banks remaining in private hands, after raising €6.5 billion from foreign investors, mostly hedge funds.  These banks entered into a servicing agreement with an Italian servicer for the management of common non-performing exposures (NPEs) of more than 300 Greek SMEs totaling €1.8 billion.  Greece’s secondary market for NPL servicers now includes 24 companies including: Sepal (an Alpha Bank-Aktua joint venture), FPS (a Eurobank subsidiary), Pillarstone, Independent Portfolio Management, B2Kapital, UCI Hellas, Resolute Asset Management, Thea Artemis, PQH, Qquant Master Servicer, and DV01 Asset Management.

By the end of December 2019, the ratio of NPLs reached 40.6% (€68.5 billion), down from 45.4% (€81.8 billion) a year earlier.  While a drop, the 40.6% ratio remains the highest in the Eurozone, well over the European average of around 3%.

Banks estimate that about 20% of non-performing exposures (NPEs) are owned by so-called “strategic defaulters” – borrowers who refrain from paying their debts to lenders to take advantage of the laws enacted during the financial crisis to protect borrowers from foreclosure or creditors’ collection even though they are able to pay their obligations.   Developing an effective NPL management strategy has been among the most difficult components of the government’s negotiations with its creditors.

Under the terms of the ESM agreement, Greece remains obliged to create an NPL market through which the loans could, over time, be sold or transferred for servicing purposes to foreign investors.  The Bank of Greece has licensed more than ten servicers, and the sale and securitization environment for non-performing loans continues to mature, with all of Greece’s systemic banks having conducted portfolio sales of secured and unsecured loan tranches since mid-2017.  The potential sale and/or transfer of Greek NPLs continues to receive interest by many Greek and foreign companies and funds, signaling a viable market.  The Greek state operates an auction platform for collateral and foreclosed assets, although the bulk of auctions still conclude with the selling bank as the purchaser of the assets.

The government introduced its “Hercules” plan in late 2019, providing guarantees to banks as an incentive to securitize €30 billion more in NPLs.  Despite an initial foray into the plan by one of the major banks, the project is on hold due to the pandemic, pending more favorable market conditions.  Once restarted, the plan aims to offload bad debt by wrapping it into asset backed securities via special purpose vehicles that will purchase the NPLs.  The sales would be financed by notes issued by the special purpose vehicles with a government guarantee for senior tranches, thereby limiting the risk to the Greek state.  “Hercules” is intended to be a voluntary scheme lasting for 18 months with a possibility of extension.

Poor asset quality inhibits banks’ ability to provide systemic financing, although the situation is slowly improving.  Deposits increased by roughly €9 billion over 2019, up from around €200 billion in early 2019, a significant improvement from the crisis years, when deposits shrunk from their highest level of €237 billion in September 2009 to around €123 billion in September 2017.  Greece’s systemic banks held the following assets at the end of 2019:  Piraeus Bank, €61.2 billion; National Bank of Greece, €59.2 billion; Alpha Bank, €55.2 billion; and Eurobank, €50.2 billion.

Few U.S. financial institutions have a retail presence in Greece.  In September 2014, Alpha Bank acquired the retail operations of Citibank, including Diners Club.  Bank of America serves only companies and some special classes of pensioners.

Greece has not announced that it intends to implement or allow the implementation of blockchain technologies in its banking transactions.

Foreign Exchange and Remittances

Foreign Exchange

Greece is a member of the Eurozone, which employs a freely floating exchange rate.  Greece is not engaged in currency manipulation for the purpose of gaining a competitive advantage.

Greece’s foreign exchange market adheres to EU rules on the free movement of capital.  Until June 2015, receipts from productive investments could be repatriated freely at market exchange rates, and there were no restrictions on, or difficulties with, converting, repatriating, or transferring funds associated with an investment.  In late June 2015, the government declared a bank holiday, during which banks were closed for two weeks, and imposed capital controls.  Capital controls placed a limit on weekly cash withdrawal amounts and restricted the transfer of capital abroad.  The government began to ease capital controls in 2016 and abolished all capital controls on stock transactions in December 2015.  On September 1, 2019, all capital controls were removed.

Remittance Policies

On September 1, 2019, all capital controls were removed (see above).

Sovereign Wealth Funds

There are no sovereign wealth funds in Greece.  Public pension funds may invest up to 20% of their reserves in state or corporate bonds.

7. State-Owned Enterprises

Greek state-owned enterprises (SOEs) are active in utilities, transportation, energy, media, health, and the defense industry.  There is no official website with a list of SOEs.

Bank of Greece: partially-owned (Greek state shares cannot exceed 35%); over 1,800 employees; governed by a Governor appointed by the government

Public Gas Corporation of Greece (DEPA): majority-owned by Greek state (65%); Net income €131 million in 2016; Total assets €3.1 billion in 2016; governed by Ministry of Development; Government is in the process of splitting the company and privatizing its infrastructure and commercial operations.

Hellenic Aerospace Industry: wholly-owned; Total assets €932.5 million in 2014; Net income €13.7 million in 2014; over 1,300 employees

Hellenic Financial Stability Fund: governed by General Council and Executive Board

Hellenic Post: majority-owned (90% by Greek state); Net income €15.5 million in 2017

Hellenic Vehicle Organization: majority-owned (51% owned by Greek state); around 400 employees; Total assets around €69 million; governed by Board of Directors

Water Supply and Sewerage Company (EYDAP): majority-owned (34% by Greek state); governed by Board of Directors

Public Power Corporation: majority-owned (51% by Greek state); Total assets €14.1 billion in 2018; over 16,700 employees

Most Greek SOEs are structured under the auspices of the Hellenic Corporation for Assets and Participations (HCAP), an independent holding company for state assets mandated by Greece’s most recent bailout and formally launched in 2016.  HCAP’s supervisory board is independent from the Greek state and is appointed in part by Greece’s creditor institutions.  Some SOEs are still supervised by the Finance Ministry’s Special Secretariat for Public Enterprises and Organizations, established by Law 3429/2005.  Private companies previously were not allowed to enter the market in sectors where the SOE functioned as a monopoly, such as water, sewage, or urban transportation.  However, several of these SOEs are planned for privatization as a requirement of the country’s bailout programs, intended to liberalize markets and raise revenues for the state.

Official government statements on privatization since 2015 have sometimes led to confusion among investors.  Some senior officials have declared their opposition to previously approved privatization projects, while other officials have maintained the stance that the government remains committed to the sale of SOEs.  The current government has expressed its commitment to moving forward with privatizations, including DEPA and some of the port assets.  Under the bailout agreement, Greece has moved forward with the deregulation of the electricity market.  In sectors opened to private investment, such as the telecommunications market, private enterprises compete with public enterprises under the same nominal terms and conditions with respect to access to markets, credit, and other business operations, such as licenses and supplies.  Some private sector competitors to SOEs report the government has provided preferential treatment to SOEs in obtaining licenses and leases.  The government actively seeks to end many of these state monopolies and introduce private competition as part of its overall reform of the Greek economy.

Greece – as a member of the EU – participates in the Government Procurement Agreement within the framework of the WTO.  SOEs purchase goods and services from private sector and foreign firms through public tenders.  SOEs are subject to budget constraints, with salary cuts imposed in the past few years on public sector jobs.

Privatization Program

The Hellenic Republic Asset Development Fund (HRADF, or TAIPED in Greek), an independent non-governmental privatization fund, was established in 2011 under Greece’s bailout program to manage the sale or concession of major government assets, to raise substantial state revenue, and to bring in new technology and expertise for the commercial development of these assets.  These include listed and unlisted state-owned companies, infrastructure, and commercially valuable buildings and land.  Foreign and domestic investor participation in the privatization program has generally not been subject to restrictions, although the economic environment during the crisis has challenged the domestic private sector’s ability to raise funds to purchase firms slated for privatization.

The August 2015 ESM bailout agreement required Greece to consolidate the HRADF, the Hellenic Financial Stability Fund (HFSF), the Public Properties Company (ETAD) and a new entity that will manage other state-owned enterprises (SOEs) into the Hellenic Corporation of Assets and Participations (or HCAP), formed by Law 4389/2016.  In March 2017, HCAP received short- and long-term guidelines from the Minister of Finance, and in September 2017, it received strategic guidelines from the Greek state (HCAP’s sole shareholder).

Privatizations are subject to a straightforward public bidding process, which is non-discriminatory and transparent.  Notable privatizations recently completed include the transfer of the 66% of Greece’s gas transmission system operator DESFA to Senfluga Energy Infrastructure Holdings, the sale of  67% of the shares of Thessaloniki Port Authority, the sale of the remaining 5% of the largest telecommunications provider shares to Deutsche Telecom, and rolling stock maintenance and railroad availability services company Rosco.

In February 2019, the government concluded the 20-year extension of the concession agreement of the Athens International Airport, worth €1.4 billion euros, and received nine expressions of interest in January 2020 for a 30% stake.  The government has launched the legal procedures necessary for privatization of ten regional ports, including Heraklion, Elefsina, and Alexandroupolis, which will be privatized through either partial concession deals or full management schemes.

In December 2019, the Ministry of Infrastructure and Transportation extended the deadline for binding bids for financing, operating, and maintaining the Egnatia motorway until June 26, 2020.  In March 2020, the commercial operations of DEPA received nine non-binding bids for its sale of a 65% stake.  Hellenic Petroleum maintains the other 35%.  The Public Power Corporation continues to consider the partial privatization of its power distribution operator.  Finally, the Hellenic Gaming Commission awarded a casino operating license to Mohegan Gaming & Entertainment and its Greek partner GEK Terna in January 2020 for an €8 billion euro project to develop Athens’ former airport site at Hellinkon into a multi-purpose complex.

8. Responsible Business Conduct

Awareness of corporate social responsibility (CSR) including environmental, social, and governance issues, has been growing over the last decade among both producers and consumers in Greece.  Greece adheres to the OECD Guidelines for Multinational Enterprises; the Greek National Contact Point (NCP) is the responsibility of the Department of International Trade in Services, International Investment Policy and Sustainable Development of the Directorate of International Trade Policy of the General Directorate of Economic and Commercial Policy of the Ministry of Economy and Development.  The NCP can be contacted through the specific service of the Ministry of Economy and Development, either for simple information, or to raise an issue related to the observance of the Guidelines, which is related to a specific instance of business behavior.  A request can be made by any interested party (trade unions, NGOs, individuals), which may be adversely affected by the conduct of a multinational enterprise.  The Greek NCP is responsible for specific instances that either take place in Greece or relate to the conduct of a Greek company operating in a country that has not adhered to the OECD Guidelines.

Several enterprises, particularly large ones, in many fields of production and services, have accepted and now promote CSR principles.  Several non-profit business associations have emerged in the last few years (Hellenic Network for Corporate Social Responsibility, Global Sustain, etc.) to disseminate CSR values and to promote them in the business world and society more broadly.  These groups’ members have incorporated programs that contribute to the sustainable economic development of the communities in which they operate; minimize the impacts of their activities on the environment and natural resources; create healthy and safe working conditions for their employees; and provide equal opportunities and professional development for employees.   In 2014, the government drafted a National Action Plan for Corporate Social Responsibility for the 2014-2020 period, to increase the number of companies that recognize and adopt a due diligence approach to ensuring responsible business conduct.  Greece has adhered to the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Afflicted and High-Risk Areas, and actively encourages the business community to adopt its recomendations.  Greece is not a member of the Extractive Industries Transparency Initiative.

9. Corruption

Greece saw a slight increase in perceptions of corruption, as it went up eight places to 60 on Transparency International’s 2019 Corruption Perception Index, from 67 in 2018.  By contrast, the country had improved since 2012, partly due to mandatory structural reforms.  Despite these structural improvements, burdensome bureaucracy is reportedly slowing the progress.  Transparency International issued a report in 2018 criticizing the government for improper public procurement actions involving Greek government ministers and the recent appointment of the close advisor to the country’s prime minister to be the head of the Hellenic Competition Commission, which oversees the enforcement of anti-trust legislation.  Transparency International released another report in October 2018, warning of the corruption risks posed by golden visa programs, mentioning Greece as a top issuer of golden visas.

On March 19, 2015, the government passed Law 4320, which provides for the establishment of a General Secretariat for Combatting Corruption under the authority of a new Minister of State.  Under Article 12 of the Law, this entity drafts a national anti-corruption strategy, with an emphasis on coordination between anti-corruption bodies within various ministries and agencies, including the Economic Police, the Financial and Economic Crime Unit (SDOE), the Ministries’ Internal Control Units, and the Health and Welfare Services Inspection Body.  Based on Law 4320, two major anti-corruption bodies, the Inspectors-Controllers Body for Public Administration (SEEDD) and the Inspectors-Controllers Body for Public Works (SEDE), were moved under the jurisdiction of the General Secretariat for Combatting Corruption.  A Minister of State for combatting corruption was appointed to the cabinet following the January 2015 elections and given oversight of government efforts to combat corruption and economic crimes.  The minister drafted coordinated plans of action, monitored their implementation, and was given operational control of the Economic Crime division of the Hellenic Police, the SDOE, ministries’ internal control units, and the Health and Welfare Services’ inspection body.  Following the September 2015 national elections, the cabinet post of Minister of State for combatting corruption was abolished, and those duties were assigned to a new alternate minister for combatting corruption in the Ministry of Justice, Transparency, and Human Rights.

Legislation passed on May 11, 2015, provides a wider range of disciplinary penalties against state employees accused of misconduct or breach of duty, while eliminating the immediate suspension of an accused employee prior to the completion of legal proceedings.  If found guilty, offenders could be deprived of wages for up to 12 months and forced to relinquish their right to regain a senior post for a period of one to five years.  Certain offenders could also be fined from €3,000 to €100,000.  The law requires income and asset disclosure by appointed and elected officials, including nonpublic sector employees, such as journalists and heads of state-funded NGOs.  Several different agencies are mandated to monitor and verify disclosures, including the General Inspectorate for Public Administration, the police internal affairs bureau, the Piraeus appeals prosecutor, and an independent permanent parliamentary committee.  Declarations are made publicly available.  The law provides for administrative and criminal sanctions for noncompliance. Penalties range from two to ten years’ imprisonment and fines from €10,000 to €1 million.  On August 7, 2019, Parliament passed legislation establishing a unified transparency authority by transferring the powers and responsibilities of public administration inspection services to an independent authority.

Bribery is a criminal act and the law provides severe penalties for infractions, although diligent implementation and haphazard or uneven enforcement of the law remains an issue.  Historically, the problem has been most acute in government procurement, as political influence and other considerations are widely believed to play a significant role in the evaluation of bids.  Corruption related to the health care system and political party funding are areas of concern, as is the “fragmented” anti-corruption apparatus.  NGOs and other observers have expressed concern over perceived high levels of official corruption.  Permanent and ad hoc government entities charged with combating corruption are understaffed and underfinanced. There is a widespread perception that there are high levels of corruption in the public sector and tax evasion in the private sector, and many Greeks view corruption as the main obstacle to the economic recovery.

The Ministry of Justice prosecutes cases of bribery and corruption.  In cases where politicians are involved, the Greek parliament can conduct investigations and/or lift parliamentary immunity to allow a special court action to proceed against the politician.  A December 2014 law does not allow high ranking officials, including the prime minister, ministers, alternate, and deputy ministers, parliament deputies, European Parliament deputies, general and special secretaries, regional governors and vice governors, and mayors and deputy mayors to benefit from more lenient sentences in cases involving official bribes.  In 2019, Parliament passed a new amendment to Article 62 of the constitution, which limits parliamentary immunity to acts carried out in the course of parliamentary duties.  Under the current constitution, parliamentary immunity applies to all acts conducted while in the office, irrespective if the act is connected to the parliamentary duties.  In addition, Parliament amended Article 86 of the constitution, abolishing the statute of limitations for crimes committed by ministers and to disallow postponements for trials of ministers.

Greece is a signatory to the UN Anticorruption Convention..  As a signatory of the OECD Convention on Combating Bribery of Foreign Government Officials and all relevant EU-mandated anti-corruption agreements, the Greek government is committed in principle to penalizing those who commit bribery in Greece or abroad.  The OECD Convention has been in effect since 1999.  Greek accession to other relevant conventions or treaties:  Council of Europe Civil Law Convention on Corruption, Council of Europe Criminal Law Convention on Corruption, and United Nations Convention against Transnational Organized Crime.

Resources to Report Corruption

Government Agency

Organization: The Inspectors-Controllers Body for Public Administration
Address: 60 Sygrou Avenue, 11742, Athens
Telephone number: +30-213-215-8800
Email address: seedd@seedd.gr

Watchdog Organization

Organization:  Transparency International Greece
Address:  Solomou 54, 4th floor, 10682 Athens
Telephone number: +30-210-722-4940
Email address: tihellas@otenet.gr

10. Political and Security Environment

There have been no major terrorist incidents in Greece in recent years; however, domestic groups conduct intermittent small-scale attacks such as targeted package bombs, improvised explosive devices, and unsophisticated incendiary devices (Molotov cocktails) typically targeting properties of political figures, party offices, privately owned vehicles, ministries, police stations, and businesses,. In addition, domestic anarchist groups often carry out small-scale attacks targeting government buildings and foreign missions.  Bilateral counterterrorism cooperation with the Greek government remains strong, and support from the Greek security services with respect to the protection of American interests is excellent.  Demonstrations and protests are commonplace in large cities in Greece. While most of these demonstrations and strikes are peaceful and small-scale, they often cause temporary disruption to essential services and traffic, and anarchist groups are known in some cases to attach themselves to other demonstrations to create mayhem.

The masterminds of Greece’s most notorious terrorist groups are currently behind bars, including leaders of November 17 and Revolutionary Popular Struggle, active between the 1970s and 1990s and responsible for hundreds of attacks and murders.  Greek authorities largely eliminated these groups in advance of the 2004 Olympic Games.  Following the Olympics, a new wave of organizations emerged, including Revolutionary Struggle, Conspiracy of Fire Nuclei, and Sect of Revolutionaries, though authorities rounded up these groups in a wave of arrests between 2009 and 2011, and again in 2014.

Current active domestic terrorist groups include” OLA,” also known as the Group of Popular Fighters or Popular Fighters Group, which claimed responsibility for the December 2018 bomb outside a private television station and the December 2017 bomb outside an Athens courthouse.  OLA also claimed responsibility for the November 2015 bomb attack at the offices of the Hellenic Federation of Enterprises, which caused extensive damage to the offices and surrounding buildings, the December 2014 attack on the Israeli embassy in Athens, which resulted in no injuries and minor damage to the building, and the attack on the German Ambassador’s residence in Athens in December 2013.  OLA also claimed responsibility for an indirect fire attack on a Mercedes-Benz building on January 12, 2014, and an attack in January 2013 against the headquarters of the then-governing New Democracy party in Athens.

11. Labor Policies and Practices

There is an adequate supply of skilled, semi-skilled, and unskilled labor in Greece, although some highly technical skills may be lacking and the COVID outbreak may also have ramifications.  Illegal immigrants predominate in the unskilled labor sector in many urban areas, and in rural areas predominately in agriculture.  Greece provides residency permits to migrants for a variety of reasons, including work.

In July 2015, Parliament adopted a new law regulating the status of non-EU foreign nationals recruited to work in the country as seasonal workers.  The law also reduced the minimum consecutive residency period in the country required for undocumented migrants to be eligible to apply for a residency permit from ten to seven years, such applications being judged on the applicant’s strong ties to the country.  The same law outlined the requirements for setting work contracts, required proof of adequate shelter for workers and imposes a €1,500 ($1,620) fine for employers who do not do so, required prepayment of at least one month’s worth of social security for each employee, provides basic labor rights to each worker, and prohibits employers from recruiting workers if found to have previously recruited workers through fraudulent means.  The law also stipulated that daily wages for non-EU foreign seasonal workers cannot be less than that of an unskillled worker.  The law granted seasonal non-EU foreign workers the same rights as citizens with respect to minimum age of employment, labor conditions, the right to association, unionism, collective bargaining, education and vocational training, employment consultation services, and the right to certain goods, services and benefits under conditions.  The same law also provided that non-EU nationals who are victims of abusive conditions or labor accidents could be eligible to apply for a residency permit on humanitarian grounds.

Asylum-seekers are eligible to apply for a work permit once they complete their first asylum interview; however, the procedures for obtaining this permit were not widely understood by asylum-seekers, non-governmental organizations (NGOs), or government officials.  As of mid-2019, the Greek Asylum Service had over 62,000 cases pending, with over 36,000 receiving asylum from 2015 to 2019.  Asylum services and receipt of applications were suspended from March 13-April 10, 2020, due to the COVID-19 pandemic.  Recognized refugees are entitled to the same labor rights as Greek nationals.  NGOs and government officials working in migrant sites reported that some asylum-seekers perform undeclared seasonal agricultural labor in rural areas.

In April 2019, Greece announced a wage subsidy scheme called “Rebrain Greece,” which provides 500 talented Greeks that moved abroad during the financial crisis with a €3,000 monthly salary if they return to Greece.  The program hopes to reinvigorate high-skilled sectors of the economy.

Greece has ratified International Labor Organization (ILO) Core Conventions.  Specific legislation provides for the right of association and the rights to strike, organize, and bargain collectively.  Greek labor laws set a minimum age (15) and wage for employment, determine acceptable work conditions and minimum occupational health and safety standards, define working hours, limit overtime, and apply certain rules for the dismissal of personnel.  There are separate national minimum wagesfor unspecialized workers aged 25 or older and workers below 25 years of age.  The latter receive 84 percent of the salary of those over 25.

On September 13, 2017, Greece’s parliament passed new legislation providing for the temporary closure of businesses in cases where employers repeatedly violate the law concerning undeclared work or safety.  Under the same law, employers are obliged to declare in advance their employees’ overtime or changes in their work schedules.  The legislation also provided for social and welfare benefits to be granted to surrogate mothers, including protection from dismissal during pregnancy and after childbirth.  Courts are required to examine complaints filed by employees against their employers for delayed payment within two months after their filing, and issue decisions within 30 days after the hearing.

The government sets restrictions on mass dismissals in private and public companies employing more than 20 workers.  Dismissals exceeding in number the limits set by law require consultations through the Supreme Labor Council (with worker, employer, and government representatives participating), and government authorization.  Based on a ministerial decision in February 2014, the competency for approving dismissals passed from the Minister of Labor to the Ministry’s Secretary General.

Greek law provides for the right of workers to form and join independent unions, conduct their activities without interference, and strike.  The establishment of trade unions in enterprises with fewer than 20 workers is prohibited.  In 2015, the law prohibiting strikes during national emergencies was amended; the new law explicitly prohibits the issuance of civil mobilization orders as a means of countering strike actions before or after their proclamation.   In July 2016, Parliament passed a law allowing military personnel to form unions, while explicitly prohibiting strikes and work stoppages by those unions.  Police also have the right to organize and demonstrate but not to strike.  Greek law also generally protects the right to bargain collectively but restricts the right to bargain collectively on wages for persons under the age of 25.  Antiunion discrimination is prohibited, and workers fired for union activity are required to be reinstated.

Company-level agreements take precedence over sectoral-level collective agreements in the private sector.  Civil servants negotiate and conclude collective agreements with the government on all matters except salaries.  Private companies allow some freedom to negotiate in-house labor agreements with employees and legislation passed between 2010 and 2013 granted companies greater freedoms to suspend and dismiss employees.  Implementation of legislation aimed at opening several “closed” professions – industries where regulation effectively creates quotas – including pharmacists, lawyers, notaries, and engineers remains uneven, with several professions effectively remaining closed.

Around 950 inspectors are authorized to conduct labor inspections, including labor inspectorate personnel and staff of the Ministry of Labor, Social Security, and Social Solidarity, the Social Insurance Fund, the Economic Crimes Division of the police, and the Independent Authority for Public Revenue.  Despite government efforts to increase inspections for undeclared, under-declared, and unpaid work, trade unions and the media alleged that, due to insufficient inspectorate staffing, enforcement of labor standards was inadequate in the housekeeping services, tourism, and agricultural sectors.  Enforcement was also lacking among small enterprises (employing 10 or fewer persons).  According to the Union of Labor Health Inspectors, authorities conducted approximately 45,000 inspections related to issues of health and safety at work, and ordered fines amounting to 7 million euros ($8.4 million) between 2015 and 2016.

Wage laws are not always enforced.  Unions and media allege that some private businesses forced their employees to return part of their wages and mandatory seasonal bonuses, in cash, after being deposited in the bank.  Several employees were reportedly registered as part-time workers but in essence worked additional hours without being paid.  In other cases, employees were paid after months of delays and oftentimes with coupons and not in cash.  Cases of employment for up to 30 consecutive days of work without weekends off were also reported.  Such violations were mostly noted in the tourism, agriculture, and housekeeping services sectors.

On July 1, 2019, Greece introduced Law 4611/2019, requiring Greek employers to provide a lawful reason when terminating employees on indefinite-term contracts, to pay social security contributions on behalf of interns and apprentices, and introduced new health and safety requirements including use of motorcycles for employment purposes.

12. U.S. International Development Finance Corporation (DFC) and Other Investment Insurance Programs

Full U.S. Overseas Private Investment Corporation (OPIC) insurance coverage for U.S. investment in Greece is currently available on an exceptional basis.  OPIC considers Greece a high-income country and is authorized to operate business in Greece only if there are strong foreign policy reasons to proceed.  OPIC and the Greek Export Credit Insurance Organization signed an agreement in April 1994 to exchange information relating to private investment, particularly in the Balkans.  Other insurance programs offering coverage for investments in Greece include the German investment guarantee program HERMES, the French agency COFACE, the Swedish Export Credits Guarantee Board (EKN), the British Export Credits Guarantee Facility (ECGF), and the Austrian Kontrollbank (OKB).  Greece is also a member of the World Bank Group’s Multilateral Investment Guarantee Agency (MIGA).

For the purposes of OPIC currency inconvertibility insurance, currency inconvertibility is not an issue as Greece has been part of the Eurozone since 2001.

In 2019, OPIC was replaced by the U.S. International Development Finance Corporation (DFC).   A DFC official visited Greece in February 2020, followed up by a March 2020 bilateral meeting underscoring the DFC’s interest in energy assets, including the underground gas storage in Kavala, regional gas or electricity interconnectors, and other energy projects.  DFC is also considering participation in the financing of the streamlining of Elefsis Shipyards, a project that needs the entry of a strategic investor according to Article 106 of the bankruptcy law, and possible privatizations of the ports of Alexandroupoli, Volos, and Kavala.

13. Foreign Direct Investment and Foreign Portfolio Investment Statistics

Table 2: Key Macroeconomic Data, U.S. FDI in Host Country/Economy 
Host Country Statistical source* USG or international statistical source USG or International Source of Data:  BEA; IMF; Eurostat; UNCTAD, Other 
Economic Data Year Amount Year Amount
Host Country Gross Domestic Product (GDP) ($M USD) 2018 $218.32 billion 2017 $203.08 billion www.worldbank.org/en/country 
Foreign Direct Investment Host Country Statistical source* USG or international statistical source  USG or international Source of data:  BEA; IMF; Eurostat; UNCTAD, Other 
U.S. FDI in partner country ($M USD, stock positions) 2018 $915.9 million 2017 $935.9 million BEA data available at
https://www.bea.gov/international/
direct-investment-and-multinational-
enterprises-comprehensive-data
 

https://www.bankofgreece.gr/en/
statistics/external-sector/direct-
investment/direct-investment—stocks
 
Host country’s FDI in the United States ($M USD, stock positions) 2018 $2.36 billion 2017 $2.2 billion BEA data available at
https://www.bea.gov/international/
direct-investment-and-multinational-
enterprises-comprehensive-data
 

https://www.bankofgreece.gr/en/
statistics/external-sector/direct-
investment/direct-investment—stocks
 
Total inbound stock of FDI as % host GDP 2018 $33.6 billion 2018 15.4% UNCTAD data available at
https://unctad.org/en/Pages/DIAE/
World%20Investment%20Report/
Country-Fact-Sheets.aspx
 
 

* Source for Host Country Data: https://www.bankofgreece.gr/en/statistics/external-sector/direct-investment/direct-investment—stocks 

Table 3: Sources and Destination of FDI 
Direct Investment from/in Counterpart Economy Data
From Top Five Sources/To Top Five Destinations (US Dollars, Millions)
Inward Direct Investment Outward Direct Investment
Total Inward 34,853 100% Total Outward 19,555 100%
Germany 7,927 22.7% Cyprus 5,032 25.7%
Luxembourg 7,566 21.7% United States 2,504 12.8%
Netherlands 5,443 15.6% China: Hong Kong 2,208 11.3%
Switzerland 3,558 10.2% Netherlands 2,024 10.4%
France 1,706 4.9% Romania 1,786 9.1%
“0” reflects amounts rounded to +/- USD 500,000.

The results are consistent with host country data found here: https://www.bankofgreece.gr/en/statistics/external-sector/direct-investment/direct-investment—stocks 

Table 4: Sources of Portfolio Investment  
Portfolio Investment Assets
Top Five Partners (Millions, current US Dollars)
Total Equity Securities Total Debt Securities
All Countries 124,346 100% All Countries 10,467 100% All Countries 113,879 100%
Luxembourg 40,976 33% Luxembourg 6,356 60.7% Luxembourg 34,620 30.4%
Italy 11,004 8.8% Ireland 1,636 15.6% Italy 10,990 9.7%
Ireland 9,551 7.7% Belgium 847 8% United Kingdom 8,059 7.1%
United Kingdom 8,134 6.5% United States 475 4.5% Ireland 7,915 7%
Spain 7,504 6% France 344 3.3% Spain 7,474 6.6%

The results are consistent with host country data.

14. Contact for More Information

Chip Laitinen, Economic Counselor
U.S. Embassy Athens, Leof. Vasilissis Sofias 91, Athina 115 21, Greece
+30 210-720-2304
ATHENS-econ@state.gov

2020 Investment Climate Statements: Greece
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