An esteemed legal practitioner with outstanding expertise in tax and business law, Ioannis Stavropoulos LL.M. is the founder and managing partner of Stavropoulos & Partners Law Office. As a tax attorney, he has represented many multinationals in tax disputes in Greek and European courts. He is regularly invited to speak at leading sectoral conferences, has authored numerous articles on tax issues, and serves as an elected member of the Board of Directors of the American-Hellenic Chamber of Commerce and Chair of the Chamber’s Taxation Committee.
In this interview to Business Partners magazine, he talks about his experience with AmCham Greece and the role of the Taxation Committee, reflects on the major milestones of his career so far, and shares his insights into the evolving taxation landscape.
This autumn marks two years since your appointment to Chair of the AmCham Greece Taxation Committee, while you are also a longstanding member of the Chamber’s BoD. Tell us about your experience with the Chamber.
AmCham Greece has been a very important part of my professional and social life. I joined the Chamber as a member in the 1990s and, in turn, became an active member of its renowned Taxation Committee, where I had the opportunity to connect and exchange ideas with prominent professionals in the legal, tax, and finance fields, participating in and supporting all legal or tax-related events.
In 2022, I was honored to be appointed as Chair of the Taxation Committee, succeeding its first—and legendary—chair, Mr. Stavros Costas, who served in this role for decades. I am eager to maintain and expand the status of this committee which has become an institutional player in tax matters in Greece. We regularly promote ideas, contribute to public dialogue, and support several institutions in shaping tax policy, and we often supply the Administration and the tax policy hierarchy with key officials. These include the former Deputy Minister of Finance, the former Secretary General of the Independent Authority for Public Revenue (IAPR), and the present Secretary General of Fiscal Policy at the Ministry of Finance, as well as experts in many legislative reform committees.
The cornerstone of the Taxation Committee’s activities is its annual Tax Forum (held once in Athens and once in Thessaloniki), which serves as a leading platform for tax experts to network, discuss key developments in the field, and attend presentations by distinguished experts from Greece and abroad. This year’s Athens Tax Forum will take place on October 31st and is anticipated with great interest as it marks 20 consecutive years of this impactful conference.
Tax matters are usually complex and require deep and tailored analysis to reach a fair and comprehensive verdict – speed is always a priority, but the quality of a judgment must not be jeopardized at any cost
You are widely recognized as one of the country’s preeminent lawyers in tax law. How did you get started in this field and what are some of the key milestones in your career thus far?
It all started by a happy coincidence in the 1980s when I was offered a job in one of the very few tax law firms existing at the time. Although my postgraduate studies in EU law had nothing to do with tax, I immediately found taxation, especially at the international and EU level, to be a very fascinating field, and I decided to focus on it. I believe that I was probably driven by my genes’ familiarity with the subject, as my father had been a senior public revenue officer in the 1960s and 1970s.
An important milestone in my career was the successful handling of a landmark EU law tax case in the 1990s at the European Court of Justice, representing Heineken. This decision attracted a lot of attention and was widely reported on and written about at the time, both locally and internationally.
I would also mention the establishment of our law firm partnership, initially with my partner in life and practice, Mrs. Evanthia Tsiri, and, later on, with my current partners and associates with whom we run a very efficient and trustworthy tax and law practice serving a considerable number of first-class corporate clients, including some (such as Philip Morris, Coca-Cola and Pfizer) of US origin.
Finally, another important and exciting period of my life was between 2012 and 2014, when, upon the invitation of my friend and prominent tax lawyer, Mr. George Mavraganis, who during those very challenging times served as Deputy Minister of Finance responsible for Tax Policy, I took part in the Tax Reform Committee. I was part of the very small circle of people who drafted and negotiated with the Troika’s Technical Assistance the major tax reform and the respective Tax Codes which were introduced and have applied since then. Working on the legislator side and drafting the tax legislation from scratch was in and of itself a very demanding job, which became even more challenging as we tried to maintain the balance between theoretical knowledge and the imperative need for speedy legislative action. The result, obviously, was not perfect, but it has produced a solid tax law corpus that survives well up to now.
Statistics and AI must be utilized to improve compliance and tax audits so that society collectively can benefit from the reduction of tax evasion
Based on your experience in the field, and looking at the current trends in taxation, where do you believe that taxation is heading today?
Speaking about Greece, I would say that taxation is gradually departing from its formal character and focusing on more subjective characteristics. Historically, and as provided in the Constitution, the tax base had to consist of a specific and actual income or asset. This made sense in the past in order to protect the taxpayer from arbitral taxes.
Gradually, however, and due to the fact that today assets are not always visible, taxation is moving toward capturing tax base even by assumptions. Techniques such as deemed income, indirect audit methods, or, in general, the “follow the money” approach, seem to be much more efficient in locating taxable income and fighting tax evasion. The interesting thing is that the courts have become quite tolerant of such abstract methods of determining taxable targets.
At the EU level, a clear trend, which is part of the famous Green Deal, is the connection of taxation with environmental targets. In this context, tax is used to punish poor performance in the energy sector and, therefore, as Mr. Gerassimos Thomas, the Director General of the DG TAXUD of the European Commission has stated, we are moving toward “behavioral taxation.”
Many consider the judicial system, especially in tax dispute cases, very slow and generally not delivering to expectations. From your point of view as a tax litigator, how would you comment on this?
First of all, we must state that the judicial system and especially the administrative courts and the Council of State, both of which rule on tax cases, deserve our respect for their high quality mission which they perform with diligence on tax matters, often being very complex matters.
On the other hand, while the number of pending cases in tax courts has dramatically decreased in recent years, the overall duration of litigation processes has not proportionally improved. While the legislator is currently taking measures in this direction, we must simultaneously encourage alternative methods of dispute resolution such as tax arbitration, following the successful example of other countries. As I mentioned above, tax matters are usually complex, especially in specialized fields such as transfer pricing, and require deep and tailored analysis to reach a fair and comprehensive verdict. Therefore, speed is always a priority, but the quality of a judgment must not be jeopardized at any cost.
What are your thoughts on AI and digital transformation in general in terms of their potential impact on taxation and tax procedures?
Digitalization has already been adopted extensively by the Tax Administration, which has been a pioneer in recent years. Tax procedures, such as filing tax returns, have been largely digitalized and the Tax Administration’s digital tools are also extensively used by other public services. We are now at a critical point where statistics and AI methods, through appropriate data analysis, must be utilized to improve compliance and tax audits so that society collectively can benefit from the reduction of tax evasion. Having said that, we must bear in mind that new digital tools, such as the myData platform, must function in a fair balance between the compliance burden imposed on taxpayers and the projected benefit of using them. The risk of prioritizing formality over substance, which was the case for many decades in our tax system, is always present.
How is the role of the private sector changing in the emerging tax landscape?
Over the years we have seen a major transformation of the tax professionals market including tax lawyers, advisors, and accountants. The big auditing firms have developed huge tax consulting sections and the number of tax lawyers has increased dramatically compared to the early days. We now have professional schemes that provide integrated services but even smaller practices which serve the field at a very competitive and high quality level. Taxation remains a very fascinating area of practice and I encourage young professionals to consider it among their choices.
