As part of its third bailout program, Greece has repealed article 21 of Law 4321/2015 with retroactive effect, which had been enacted earlier in the year and introduced a 26% withholding tax on certain cross border transactions ({News-2015-04-28/A/4- previous coverage}). The tax, introduced in March 2015, was a prepayment of tax for the payer, and if not made, rendered the expense non-deductible.
It was to apply in a number of cases, including for payments to residents of non-cooperative ju…