Katerina Sideromenou

Of Counsel

Katerina is an of counsel of the Law Firm

Her practice focuses on tax and company law. Katerina advises domestic and multinational corporations and institutions as well as individuals during the conduct of tax audits and represents them in all phases of tax disputes, both in judicial and out-of-court level. Katerina has also great experience in a variety of direct and indirect taxation matters and she provides high level advisory services to domestic and international clients on taxation and tax planning implications arising in the course of their business.

Highlights of her work in the fields of her expertise include

Advised and represented one of the top 3 Greek banks in relation to its claims against Tax Authorities for the refund of tax that has been withheld on interest accrued, among others, on bonds.
Advised major domestic entity in relation to the tax treatment of its transactions with cross-border entities established in countries having a preferential tax regime.
Advised and represented Greek financial institution in relation to adjustment of input VAT paid for the purposes of real estate construction.
Advised and represented one of the biggest telecommunication companies in relation to the imposition of stamp duties on intra-group cash pooling transactions.
Advised Greek insurance company in relation to the tax treatment of contributions paid by the company and its employees in favour of a Pension Fund set up by the company.
Advised Greek corporation with regard to its dispute with the Tax Authority in connection with the deductibility of a tax loss of past fiscal years.
Advised and represented international group in relation to the alleged personal liability of two executives of the group (who have acted as directors of a Greek company acquired by the group) for the company’s tax debts.
Advised a big construction company on the spin – off of its RES sector with regard to the transaction’s tax implications.
Advised a big energy and metal company in relation to an issue of tax – exempt reserve fund.
Represents the Greek subsidiary of a major player of the food industry in relation to transfer pricing issues following a tax audit.
Advising a payment institution on a withholding tax matter for payments it has made for the use of cloud computing platform.
Advised a subsidiary of a leading real estate development company in Greece on the tax treatment of losses representing the undepreciated value of its demolished buildings.
Advised and represented a leasing company on its claim for the recovery of overpaid VAT following a VAT adjustment due to due to the formal write-off of a contractual debt of its lessee, following a court-approved rehabilitation agreement under the Greek Bankruptcy Code.
Advised and represented an energy company in relation to its dispute with the tax authorities for the implementation of Transfer Pricing Guidelines on the transfer of its stake in a wind energy company to an affiliated entity.
Advised a foreign investment fund in relation to the application of Parent – Subsidiary Directive on interest payments made from its domestic subsidiaries.

Prior to joining the firm, Katerina has worked in the legal department of Nordea Investments Funds S.A, located in Luxembourg.

Katerina, besides Greek, is fluent in English and German and has a good understanding of French.

Education

Athens University of Economics and Business – Post Graduate Diploma in Tax Law, 2016.
Democritus University of Thrace – LLM in Commercial law with Specialisation in Competition law, 2015.
Freie University of Berlin – Master in Business Law, 2013.
Democritus University of Thrace School of Law – Law Degree (Ptychion), 2010.

Publications

Comment on the decision of Council of State no. 249/2024, Article 5 para. 10(b) of Law 2523/1997 is unconstitutional to the extent that the existence and degree of fault of the offender is not taken into account for the imposition of the sanction provided for therein, Business and Company Law (Greek law bulletin), 4/2024, p. 407.

Comment on the decision of Administrative Court of Appeal of Larissa no. 284/2024, Relationship of habitual residence according to Article 3 of D.247/13/1.3.1988 and tax residence under the Income Tax Code, Business and Company Law (Greek law bulletin),11/2024, p. 1114.

Comment on the decision of Council of State no. 278/2023, Annulment of the administration’s omission to issue the administrative act provided for in article 82 par. 6 Law 2961/2011 due to continued inaction – Obligation of immediate application of the law by the tax authority until the relevant administrative act is issued, Theory and Praxis of Administrative Law (Greek law bulletin), 7/2023, p. 784.

Comment on the decision of Administrative Court of First Instance of Thessaloniki no. 4015/2021, Joint and several liability – Submission of an application for the inclusion of a jointly liable party under the provisions of the “new” Article 50 of the Code of Tax Procedure, as amended by Article 34 of Law 4646/2019, with a memorandum before the Court, Business and Company Law (Greek law bulletin),2/2022, p. 275.

Comment on the decision of Council of State no. 984/2020, Overpricing between affiliated undertakings – Article 19 para. 4 Law 2523/1997 is not applicable if the agreed price is identical to the one indicated in the relevant invoice, Business and Company Law (Greek law bulletin), 7/2020 p. 901.

Comment on the decision of Council of State no. 1057/2019, Inheritance Tax – Potential payment of the tax through transfer of immovable property to the Greek State, Enterprise (Greek law bulletin), 2019, p. 938.

(With P. Pantazopoulos), Greek Law Digest (Disputing Acts and Omissions of The Tax Authority), 2016.

Bar Admissions

Member of the Athens Bar Association since 2012. Qualified to practice before the Supreme Court.