Professor Katerina Perrou
Associate Research Fellow
LLB (Law School, University of Athens, Greece); LLM in Public Law (Law School, University of Athens, Greece); PhD in International Taxation (IALS, University of London, UK); Qualified Lawyer, member of the Athens Bar Association (Greece)
Research Interests
International and EU tax law; tax policy; legislative drafting (primary law, secondary legislation, circulars, manuals, guidelines); tax treaties; tax treaty negotiation and drafting; cross-border tax dispute resolution; tax treaty arbitration; transfer pricing; human right and taxation; democracy and international tax law making; public economic law; financial and banking regulation; public finance; international economic law; investment treaties.
Additional Professional Information
- Assistant Professor of Public Law (Public Economic Law, Tax Law and Public Finance), Law School, National and Kapodistrian University of Athens, Greece;
- Currently serving as: Legal Counsel to the Governor, Independent Authority for Public Revenue, Greece
Other Information
Prof. Katerina Perrou has substantial experience in providing technical assistance to the tax authorities third countries in the EU neighbourhood regarding the harmonization of their legislation with the EU acquis; the implementation of public finance reforms; and the development and implementation of transfer pricing legislation and anti-tax abuse measures.
She has also substantial experience in providing judicial training both through the European Judicial Training Network (EJTN) and at the National (Hellenic) School of Judges.
From April 2016 until August 2018 she conducted research as a Postdoctoral Fellow on Dispute Resolution and Taxpayer Rights; and Tax Treaty Related Issues at the IBFD, Amsterdam, the Netherlands.
Selected Publications
2024
Taxpayer participation and rights in MAP procedures, co-authored with P. Baker, in: H. Mooij (ed), International Tax Disputes, Elgar, 2024
Book review: Robert Attard, Paulo Pinto de Albuquerque, Taxation at the European Court of Human Rights, (Wolters Kluwer, 2023, xvii + 207 pp, €103) ISBN 9789403518961 (hb), Human Rights Law Review, Volume 24, Issue 1, March 2024, ngad041, https://doi.org/10.1093/hrlr/ngad041
2023
Sanctions Imposed on Digital Platforms under DAC7 and the Freedom to Conduct Business, European Taxation, issue 5, 2023
Transfer pricing adjustments and the elimination of double taxation in purely domestic situations, International Transfer Pricing Journal, issue 1, 2023, pp. 35-37
Third party liability for the payment of taxes and protection of third parties’ rights, co-authored with P. Baker and P. Pistone, World Tax Journal, issue 1, 2023
Chapter 11 – International Tax Law and Public International Law, co-authored with Ch. HJI-Panayi, in: F. Haase and G. Kofler (eds), The Oxford Handbook of International Tax Law , OUP, 2023
2022
Economic Freedom in the EU and measures to protect public revenue, (in Greek) Nomiki Vivliothiki 2022
Transfer pricing adjustments and the elimination of double taxation in purely domestic situations, International Transfer Pricing Journal, issue 1, 2023
Fundamental Rights and Tax Procedures, (in Greek) Nomiki Vivliothiki 2022
The application of the special tax on real property in: Law of Real Property, e-themis (eds), (in Greek) Nomiki Vivliothiki 2022
Critical review of the ATAD implementation – _The implementation of the ATAD in Greece, (double blind peer reviewed), Intertax 2022, n.8/9, σελ. 619 επ.
New tax incentives for business restructurings, European Taxation 2022, n. 9, published online 10 August 2022
2021
Case Law Note: The Application of the EU Charter of Fundamental Rights to Tax Procedures: Trends in the Case-Law of the Court of Justice, Intertax vol. 49, Issue 10 (2021), pp. 853-861
Chapter 3 - Taxpayers’ rights in trans-border dispute on tax matters, in: E.A. Aucejo & A.O.Rayo (eds), Global Tax Governance, Taxation on Digital Economy, Transfer Pricing and Litigation in Tax Matters (MAPs+ADR). Tax Policies for Global Sustainability. Ongoing U.N. 2030 (SDG) and Addis Ababa Agendas, Thomson Reuters 2021, pp. 323-332.
Chapter 21 – Greece, in: W. Haslehner & M. Lamensch (eds), Taxation and Value Creation, EATLP International Tax Series, Vol. 19, IBFD 2021, pp. 413-426.
Greece – Rollback of APAs in Greece, International Transfer Pricing Journal, 2021 (Volume 28), No. 3 (Next issue), published online: 24 March 2021
Greece – Making the Mutual Agreement Procedure more effective in Greece: a Commentary on the Guidelines for the conduct of MAPs, European Taxation 2021 (Volume 61), No. 2/3, published online 12 January 2021
Chapter 3: The Use of a Third Person other than a Court in Order to Deal with Tax Disputes: The Greek Experience, in: P. Pistone and J. DeGoede, Flexible Multi-tier Dispute Resolution in International Tax Disputes, IBFD 2021, pp. 43 et seq.
Chapter 11: Using Mediation for the resolution of cross-border tax disputes, in: P. Pistone and J. De Goede, Flexible Multi-tier Dispute Resolution in International Tax Disputes, IBFD 2021, pp. 197 et seq.
2020
Greece – Alternative taxation regimes for new tax residents, European Taxation, 2020 (volume 60), No. 12, published online: 5 November 2020
Chapter 12 - Tax Justice in the Post-BEPS Era: Enhanced Cooperation Among Tax Authorities and the Protection of Taxpayer Rights in the EU, in: D. de Cogan and P. Harris, Tax Justice and Tax Law (Hart Publishing, 2020), co-authored with Prof. Christiana HJI Panayi
Greece – Tax loss utilization through company reorganizations, European Taxation 2020 (vol. 60) no. 2/3
Chapter 15: Greece, in: M. Lang et al (eds), Tax Treaty Arbitration, pp. 367 et seq.
Chapter 24 – Fundamental rights in EU tax law, in HJI Panayi, Haslehner and Traversa (eds) Research Handbook on European Union Taxation Law, Elgar 2020, pp. 511 et seq.
Chapter 25 – Dispute resolution and taxpayer participation, in HJI Panayi, Haslehner and Traversa (eds) Research Handbook on European Union Taxation Law, Elgar 2020, pp. 541 et seq.
2019
Chapter 1: Greece: Scope of Application of the Treaty in Case of Income from Unknown Sources, in: E.C.C.M. Kemmeren et.al. (eds), Tax Treaty Case Law around the Globe 2018, IBFD/Linde 2019, pp. 3 et seq.
Chapter 11: Greece: Attribution of Profits to PE and Limitations of Deductible Expenses under Domestic Law, in: E.C.C.M. Kemmeren et.al. (eds), Tax Treaty Case Law around the Globe 2018, IBFD/Linde 2019, pp. 113 et seq.
Taxpayer Rights and Taxpayer Participation in Procedures Under the Dispute Resolution Directive, Intertax, Volume 47 (2019) Issue 8/9, pp. 715–724 (double blind peer-reeviewed)
Co-authored
Towards a Standing Committee Pursuant to Article 10 of the EU Tax Dispute Resolution Directive: A Proposal for Implementation, Sophia Piotrowski, Roland Ismer, Philip Baker, Jérôme Monsenego, Katerina Perrou, Raffaele Petruzzi, Ekkehart Reimer, Fernando Serrano Antón, Lukasz Stankiewicz, Edoardo Traversa, Jasna Voje, Intertax, Volume 47 (2019) Issue 8/9, pp. 678–692 (double blind peer-reviewed)
2018
“The Ombudsman and the Process of Resolution of International Tax Disputes – Protecting the “Invisible Party” to the MAP, World Tax Journal 2018 (volume 10), no. 1 (double blind peer-reviewed)
Chapter 18: Greece in Improving Tax Compliance in a Globalized World (C. Evans et al. eds., IBFD 2018), Online Books IBFD.
Chapter 10: Interest and penalties in Tax Procedures Code, Systematic per Article Interpretation of Law 4174/2013, (J.G.Photopoulos ed., Sakkoulas 2018) (in Greek), pp. 1413-1539, pp. 1579-1600, and pp. 1631-1746
2017
“Making Transfer Pricing Adjustments Effective: Are the Tax Authorities Obliged to Reopen Fiscal Years for Which Corrective Tax Assessments Have Been Issued, after a Full Tax Audit?,” 24 Intl. Transfer Pricing J. 2 (2017), Journals IBFD, pp. 147 et seq.
“Foreign Corporate Income Tax Credit – A Case of Treaty Override Caused by Domestic Case Law,” 57 Eur. Taxn. 2/3 (2017), Journals IBFD, pp. 105 et seq.
“Commission v Greece: Greek preferential inheritance tax for bequests of which the beneficiaries are non-profit-making legal persons.” Comment on the case law, Highlights and Insights on European Taxation, Volume 9, p. 290, Wolters Kluwer 2017 [ISSN: 1876-665X]
2016
“New Law Amends Transfer Pricing Documentation Rules and APA Procedure,” 23 Intl. Transfer Pricing J. 6 (2016), Journals IBFD, pp. 517 et seq.
“Tax Law Disputes before Investment Arbitration Panels: Practical Experience,” 56 Eur. Taxn. 10 (2016), Journals IBFD, pp. 451 et seq.
“Greece – Clarifications on transfer pricing published”, Intl Transfer Pricing J, vol. 23, 2, pp. 161 et seq.
“Dispute resolution procedures in international tax matters”, Greece, Branch Report in: IFA, Cahiers de droit Fiscal International, volume 101 (2016 Madrid Congress)
2015
“Participation of the taxpayer in MAP and arbitration: Handicaps and Prospects”, Chapter 11 in: M. Lang - J. Owens (eds), International Arbitration in Tax Matters, IBFD, December 2015
“The practical protection of taxpayers’ fundamental rights”, Greece, Branch Report in: IFA, Cahiers de droit Fiscal International, volume 100B, 2015 Basel Congress
“Greece: New CFC rules”, European Taxation, vol. 55, 4, pp. 173 et seq.
“Greece: Legislation requires withholding tax to be paid on certain payments to branches established in Greece but not payments between Greek payments”, European Taxation, vol. 55, 1, pp. 33 et seq.
“Greece: APA guidance released by tax authorities”, Intl Transfer Pricing J, vol. 22, 2, pp. 116 et seq.
2014
“Taxpayer participation in DTC dispute resolution”, IBFD Doctoral Series, volume 28 (Book; PhD thesis)
“Greece: Decision of the Secretary General for Public Revenue on transfer pricing documentation rules”, ITPJ 2014, vol. 21, 6, pp. 457 et seq.
“Greece: taxes covered – is an extraordinary levy on business profits covered?”, in: M. Lang e.a. (eds), Tax Treaty Case Law around the Globe 2013, IBFD/Linde 2014, pp. 13 et seq.