According to par.1 of article 66 of Income Tax Code (ITC), a CFC is a foreign legal person, or foreign legal entity, or a foreign permanent establishment of which the profits are not subject to tax or are exempt from tax, if the following conditions are met cumulatively:
 
a) in the case of an entity, the taxpayer by itself, or together with its associated enterprises holds a direct or indirect participation of more than 50 percent of the voting rights, or owns directly or indirectly more than 50 percent of capital or is entitled to receive more than 50 percent of the profits of that entity; and

b) the actual corporate tax paid on its profits by the entity or permanent establishment is lower than the difference between the corporate tax that would have been charged on the entity or permanent establishment under the Greek corporate tax system of the taxpayer that would be due by such person in Greece and the actual corporate tax paid on its profits by the entity or permanent establishment; and

c) if more than thirty percent (30%) of net income before tax realized by the legal person or legal entity falls into one or more certain categories as defined in paragraph 3 of the same article (ITC). 

2. An associated enterprise means:
(a) a legal person or legal entity in which the taxpayer holds, directly or indirectly, voting rights or participation in the capital or a right to participate in the profits by twenty-five percent (25%) or more,
(b) a natural or legal person or legal entity that holds, directly or indirectly, voting rights or participation in the capital or a right to participate in the profits by twenty-five percent (25%) or more in a taxpayer.

If a natural or legal person or legal entity holds, directly or indirectly, voting rights or participation in the capital or a right to participate in the profits by twenty-five percent (25%) or more in a taxpayer and in one or more legal persons or legal entities, all relevant legal persons or legal entities, including the taxpayer, are also considered associated enterprises.