Greece has put in place a special tax framework for the 40-year concession of Kalamata International Airport, offering the private operator exemptions and other protections covering value-added tax, accumulated tax losses, property-related charges and a range of transactions linked to the agreement.
The concession of Kalamata International Airport “Captain Vassilis Constantakopoulos,” the main air gateway to Greece’s southwestern Peloponnese and the increasingly popular Messinia tourism region, includes a €125 million investment program aimed at upgrading and expanding the airport’s infrastructure.
The agreement was ratified under Greek Law 5323/2026. Management of the airport is being transferred to an investment consortium comprising Fraport, Delta Airport Investments and Pileas Holdings. Greece’s Independent Authority for Public Revenue, known by its Greek acronym AADE, has circulated details of the concession’s tax provisions, clarifying how taxes, VAT, transfers and other financial transactions will be treated over the life of the agreement.
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One of the provisions concerns share transfers made to the concession grantor so that it can acquire and maintain a 10% stake in both the share capital and voting rights of the company operating the airport. Those transfers are exempt from taxes, duties, third-party levies and other charges.
The concession also provides particularly favorable treatment for tax losses accumulated by the airport operator. Such losses can be carried forward and offset against future taxable profits without a time limit, giving the concessionaire considerably more flexibility to absorb losses that may arise during the investment-heavy early years of the project.
The overall investment expenditure, including construction costs and the equipment required for the airport’s development, will be depreciated in accordance with the relevant provisions of Greece’s Income Tax Code.
Another provision concerns the financial contribution made by the Hellenic Corporation of Assets and Participations, Greece’s state-owned asset-management company, commonly known as HCAP or Growthfund. The contribution is classified as a capital subsidy and is exempt from VAT, corporate income tax, withholding tax, Greece’s Digital Transaction Duty and other comparable charges.
The concessionaire will also avoid real-estate taxes on the airport property. The rationale set out in the agreement is that the operator doesn’t acquire a property right over the concession area itself. At the end of the 40-year term, the return of the concession to the Greek state will similarly be exempt from property-transfer tax and related charges.
The agreement establishes specific rules for VAT refunds, an important consideration given the scale of the capital expenditure planned for the airport. Any VAT credit balance owed to the concessionaire must be refunded within the period prescribed by Greek law and, in all cases, no later than 90 days after the relevant application is submitted.
A longer deadline applies to the first VAT refund, which may take as long as six months. If the authorities miss the applicable deadlines, interest is payable on the delayed amount. The financial payments at the heart of the concession receive favorable tax treatment as well. The concession fee and the contribution paid by the operator to the concession grantor and the Greek state, respectively, are exempt from taxes and can be deducted from revenue in the financial year in which they are paid.
The agreement also exempts from the Digital Transaction Duty both contracts assigning VAT-related receivables and compensation payments to the concessionaire that arise under the terms of the concession.
Taken together, the provisions create a relatively predictable tax environment for a project whose economics stretch across four decades. They limit the tax burden associated with the concession’s structure and large upfront investment requirements, while setting explicit rules for issues such as loss carryforwards and VAT refunds that can have a significant impact on cash flow.
