“There were not enough exemptions before,” explains Daphne Cozonis, of law firm Zepos & Yannopolous – Taxand. “The thin cap rules in Greece are not very old. They only came into effect in 2009 so as businesses become aware of these rules and how they apply, some cannot operate under thin capitalisation rules due to the way they are structured. For example, not even banks were exempt so now, over time, things are adapting.”