Greek holding company bank account: how it is obtained and run

What sets a Greek holding apart from a trading company

A Greek holding company bank account centralises dividends, intragroup loans and capital contributions for a company, usually an AE or IKE, whose main activity is owning shareholdings. Because the holding sells neither goods nor services, the bank expects few but large flows, each linked to a subsidiary, and reviews the group, its substance in Greece and its beneficial owners.

A Greek holding company, usually set up as an AE or IKE, sells neither goods nor services, so a holding company account shows quite different flows: its income consists of dividends, capital gains and intragroup interest. The bank therefore expects few but large flows, each of which it links to a subsidiary.

Exemption for dividends received from subsidiaries

The Greek income tax code exempts dividends paid by qualifying subsidiaries, subject to conditions on shareholding percentage and minimum holding period. The relationship manager often asks for the group chart and percentages to understand the amounts expected on the holding account.

5% withholding tax on distributions

Dividends paid by a Greek company are in principle subject to 5% withholding tax, which a tax treaty or the Parent-Subsidiary Directive may reduce or eliminate. The holding's account must make it possible to document each distribution and the tax withheld.

Place of effective management and substance in Athens

A legal entity is Greek tax resident if it is incorporated there or effectively managed there. Banks look at where the board meets, who decides, and whether the holding has an office, a director or staff in Greece.

CFC rules on controlled foreign companies

Greece applies controlled foreign company rules derived from the EU ATAD directive, which can bring passive income held in a low-taxed subsidiary back into the tax base. The bank may ask how the structure complies with these rules.

Advances to Greek subsidiaries and transfer pricing

Advances between the holding and its subsidiaries must carry arm's-length terms and be documented, as Greece requires transfer pricing files above certain thresholds. Loan agreements and repayment schedules are requested for large transfers.

Shipowning groups and family holdings

Many Greek holdings sit above shipping, hotel or family property companies. These long-standing structures often include foreign companies further up, which leads the bank to trace the entire ownership chain up to the individuals.

Opening the account and the first funding

For a holding, National Bank of Greece reviews the GEMI extract, the articles, the share register, the beneficial owner register filing and the accounts of the main subsidiaries. The first contribution must come from an account in the shareholder's name, with proof of origin.

Cross-border arrangements subject to DAC6

Arrangements showing certain cross-border tax hallmarks must be reported by intermediaries or the taxpayer under the DAC6 directive, transposed in Greece. A holding placed between several countries is frequently subject to this prior analysis.

CRS exchange on entity accounts and Form 3916

The bank classifies the holding as an active or passive entity under CRS and, if passive, reports its controlling persons to their country of residence. A French-resident shareholder also declares accounts over which they hold signing power on Form 3916.

Documents for a Greek holding company bank account

The file for a Greek holding company bank account is more substantial than that of a trading company, because the bank examines the whole group. Prepare the up-to-date GEMI extract, the articles, the share register, the beneficial owner register filing and the accounts of the main subsidiaries. A group chart showing shareholding percentages down to the individuals is almost always requested.

Add the identity documents and proof of address of the directors and significant shareholders, together with a note describing the purpose of the holding: which shareholdings it owns, where dividends will come from, and which intragroup loans are planned. This note helps the relationship manager understand why flows will be rare but large, and not mistake them for anomalies. That context makes the whole review smoother.

For the first funding, prepare proof of the source of funds: a statement of the shareholder's account from which the contribution comes, a loan agreement, a sale deed or a capital increase resolution. It is better to question the adviser beforehand and gather everything at once than to send documents in several rounds.

Substance: what the bank asks a Greek holding company

A Greek holding company carries on no trading activity, but the bank wants to know where it is actually managed. It looks at where the board meets, who takes the decisions, and whether there is an office, a director or staff in Greece. A shell with no local presence prompts more questions than a structure whose decisions are genuinely taken in Athens.

Prepare clear answers: minutes of meetings, service contracts with a local provider, evidence of the registered office address. Banks do not always require the same proof, and each institution assesses substance in its own way, so ask what it expects before putting the file together. These elements also relate to the company's tax residence, which is a matter of Greek law.

If the holding includes foreign companies above or below it, explain the role of each. The controlled foreign company rules and the DAC6 directive lead the bank to analyse the logic of the structure. A coherent commercial explanation, validated by your tax adviser, noticeably reduces back-and-forth and reassures the compliance team about the soundness of the arrangement. That reassurance often speeds up the decision.

Common mistakes with a holding company account

The first mistake is to present the holding as an operating company or, conversely, to stay vague about its role. A holding's flows, dividends, intragroup interest and capital contributions, do not resemble those of a business selling products. Announce them clearly, subsidiary by subsidiary, so that large amounts are not read as suspicious activity. Clarity at the start prevents misunderstandings later.

The second mistake is to neglect loan documentation. Advances between the holding and its subsidiaries must be contractual, remunerated on arm's-length terms and accompanied by repayment schedules. Without a contract, large transfers lead to requests for justification, or even a temporary block. Also keep a record of the tax withheld on distributions, since the bank or the authorities may ask for it.

A third frequent mistake is to underestimate the timeline. A holding attached to a family group or to several countries takes longer to review than a simple company, especially as the bank traces the ownership chain up to the individuals. Allow time, answer follow-up requests quickly, and avoid scheduling an urgent payment before you have received access to the account. Plan ahead.

Running a Greek holding company: traceability and reporting

Once the account is open, traceability is essential. Every dividend received, every loan granted or repaid and every contribution must be linked to a document: a shareholders' resolution, a contract, a subsidiary's statement. Keep up-to-date accounts and a digital folder of supporting papers, so you can answer quickly if the bank or the authorities raise a question. This also helps the accountant at year-end.

On transparency, the bank classifies the holding as an active or passive entity under CRS; if passive, the people who control it are reported to their country of residence. A shareholder resident in France must also check their own obligations, notably Form 3916 for accounts over which they hold signing power. Tax advice is useful before the first transaction. A short consultation is usually enough to clarify the position.

Finally, tell the bank about any important change: a shareholder joining or leaving, a new subsidiary, a change of corporate purpose, a move of the registered office or of the director. These events can alter the compliance analysis and, sometimes, the CRS classification. Informing the bank in time beats answering urgently a request for updates that could temporarily freeze how the account works.