I don't speak Greek, so I can't tell you where exactly this is written. But it is about corporate tax residence and permanent establishment:
https://taxsummaries.pwc.com/greece/corporate/corporate-residencehttps://www.taxlaw.gr/en/practice-a...ablishment-of-foreign-undertakings-in-greece/
The purpose of CFC rules is just to "catch" setups that would not be covered by other rules. It is very common for them to only apply to passive income companies, because such companies require little substance.
If it's an operative business that is run from Greece, then other laws already cover this in detail, so it's not necessary for CFC laws to apply to them as well.
https://taxsummaries.pwc.com/greece/corporate/corporate-residencehttps://www.taxlaw.gr/en/practice-a...ablishment-of-foreign-undertakings-in-greece/
The purpose of CFC rules is just to "catch" setups that would not be covered by other rules. It is very common for them to only apply to passive income companies, because such companies require little substance.
If it's an operative business that is run from Greece, then other laws already cover this in detail, so it's not necessary for CFC laws to apply to them as well.