Alternative Taxation for High-Net-Worth Individuals Relocating to Greece
Greece offers a special alternative taxation regime for qualifying individuals who transfer their tax residence to Greece and make a qualifying investment in the country.
The regime provides a predictable tax framework for qualifying foreign-source income, making Greece an attractive option for high-net-worth individuals considering relocation, investment, and long-term residence.
Our team provides legal guidance throughout the process, from assessing eligibility and structuring the investment to preparing and submitting the application.
For individuals with significant income and assets outside Greece, becoming a Greek tax resident requires careful planning.
Article 5A of the Greek Income Tax Code allows qualifying individuals to opt for an alternative method of taxation of income arising abroad, subject to specific eligibility and investment requirements.
Fixed annual tax on qualifying foreign-source income.
Additional annual tax for each qualifying family member included in the regime.
The alternative taxation regime may apply for up to 15 tax years.
Minimum qualifying investment for applicants who need to satisfy the investment condition.
The regime is intended for individuals who are tax residents outside Greece and wish to transfer their tax residence to Greece.
To qualify, the applicant must generally demonstrate that they:
An important exception applies to individuals who have obtained and maintain a Greek residence permit for investment activity under the applicable investment-residence provisions. In such cases, the €500,000 investment condition under Article 5A does not have to be met separately.
The qualifying investment does not have to be limited to real estate.
Under the current framework, qualifying investments can include investments in:
Investment in property located in Greece.
Investment in businesses established in Greece.
Investment in qualifying movable securities.
Acquisition of shares or interests in Greek legal entities or entities established in Greece.
The investment may be made by the applicant, by a qualifying family member, or through a legal entity in which the applicant holds the majority of shares or interests, subject to the applicable requirements.
Once approved under Article 5A, the individual pays a fixed annual tax of €100,000 on income arising abroad, regardless of the amount of such income.
The applicant may also request that the regime be extended to qualifying family members. The additional tax is €20,000 per family member per year.
The tax is paid annually in a single instalment. Under the current legislation, the annual payment deadline has been changed from the previous July deadline to the last working day of December, while the first year’s tax is due within 30 days of approval of the application.
The regime can be extended to qualifying family members of the applicant.
This can provide an attractive solution for international families who are considering relocating their tax residence to Greece together.
For each family member included in the regime, an additional €20,000 annual tax applies.
Under the current rules, qualifying relatives include the applicant’s spouse or civil partner and relatives in the direct ascending or descending line, subject to the statutory conditions.
The Non-Dom regime is particularly relevant for individuals who already hold substantial assets and investments outside Greece.
The current legislation also provides a specific exemption from Greek inheritance and gift tax for movable property located abroad that is transferred by reason of death or gift, subject to the conditions of Article 5A.
Because the treatment of assets can depend on their nature, location, ownership structure, and the circumstances of the transfer, individual legal and tax advice is essential before restructuring assets or changing tax residence.
Transferring your tax residence is a significant decision that should be planned before the move to Greece.
We review your tax-residency history, family circumstances, investment plans and existing assets.
We assess the available qualifying investment structures and help determine the appropriate legal route for your circumstances.
We coordinate the preparation and review of the documentation required for the application and the investment.
We assist with the submission of the application to the competent Greek tax authorities and monitor the procedure.
We remain available to assist with the legal aspects of your relocation and your ongoing obligations under the regime.
For international investors, the Greek Non-Dom regime can also be considered alongside the Golden Visa programme.
However, these are two different legal frameworks.
The Golden Visa provides residence rights through qualifying investment, while Article 5A concerns the alternative taxation of foreign-source income following the transfer of tax residence to Greece.
Depending on the individual’s circumstances, the two may be relevant as part of a broader relocation and investment strategy. Each should be assessed separately before making an investment or changing tax residence.
The decision to transfer tax residence involves more than simply choosing a tax regime.
Your existing investments, company structures, family circumstances, residence status and international tax position can all affect the way the move should be structured.
Our team can help you understand the Greek legal framework and coordinate the steps required to make the transition as clear and well-structured as possible.
Whether you are looking to relocate, invest, or establish a long-term presence in Greece, we can help you assess whether the Greek Non-Dom regime is appropriate for your circumstances.
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