From very old times but also today, within the framework of ongoing globalization, we often encounter cases of individuals who live and work in one country but earn income from sources located in another country. For example, a Greek tax resident acquires income from a business based and operating in the Netherlands, or a Canadian tax resident earns income from properties in Greece, or a Chinese company operates in Greece through its branch, etc.

The general rule in income taxation is that the taxpayer who has tax residence in Greece is subject to tax for their taxable income arising in Greece and abroad, that is, for their worldwide income acquired within a certain tax year. Similarly, the taxpayer who does not have tax residence in Greece is subject to tax for their taxable income arising in Greece and acquired within a certain tax year.

In each country, there is a different tax system depending on each country's economic and social policy. Therefore, a resident of Greece who earns income, for example, in Egypt, is taxed on that income in the country where it is earned according to the applicable tax system of Egypt, and then there is an obligation to declare and tax it again in Greece, taking into account or disregarding the tax paid for that income abroad.

To address problems arising from the double taxation of income in the above cases, countries started entering into agreements with each other to achieve the taxation of income or capital from only one country, while also determining which country that will be.

These intergovernmental agreements are called Double Taxation Avoidance Agreements (DTAA). They are concluded between two states - parties, which is why they are often referred to as bilateral international agreements for the avoidance of double taxation.

Greece has started signing DTAA with many countries from the 1950s until today. As a member of the Organization for Economic Cooperation and Development (OECD), our country follows the Model Convention of the OECD in the negotiations for the conclusion of DTAA with other member and non-member countries of the OECD. This Model Convention includes:
a) the text of the DTAA and
b) the explanatory comments (Commentaries) that interpret and explain the provisions of the Model.

The OECD Council, on November 21, 2017, approved the update of the 2017 model in the OECD model tax convention, which implements the amendments made in 2015.

Double Taxation Avoidance Agreements (DTAA) are an integral part of Greek tax law.

By adopting the above Convention as a model, Greece has created a network of 57 bilateral agreements for the avoidance of double taxation, which are presented in this edition.