A Competitive Tax Regime for High-Net-Worth Individuals
In recent years, Greece has established a particularly attractive framework for high-net-worth individuals seeking to transfer their tax residence to the country.
The so-called Non-Dom Regime, provided for under Article 5A of Law 4172/2013 (Greek Income Tax Code), allows, subject to specific conditions, the taxation of all foreign-source income through an annual lump-sum tax of €100,000, regardless of the actual amount of such income.
The regime is of particular interest to international investors, entrepreneurs, company shareholders, and High-Net-Worth Individuals (HNWIs) with substantial income or investments outside Greece.
What Are the Main Eligibility Requirements?
To qualify for the tax regime under Article 5A, an individual must first transfer their tax residence to Greece.
In addition, two key conditions must be met cumulatively:
First, the applicant must not have been a Greek tax resident for seven (7) out of the eight (8) years preceding the transfer of their tax residence to Greece.
Second, an investment with a total value of at least €500,000 must be made in Greece.
The investment may be carried out by the taxpayer personally, by a relative, or through a legal person or legal entity in which the taxpayer holds the required majority interest.
Eligible investments may include, among others:
- Real estate in Greece;
- Greek businesses;
- Securities;
- Shares or equity interests;
- Other qualifying investments in accordance with the applicable regulatory framework.
The investment must be completed within three (3) years from the date of submission of the application.
By way of exception, the investment requirement does not apply to individuals who have obtained and continue to hold a residence permit for investment activities in Greece, subject to the specific conditions laid down in the relevant legislation.
How Is Foreign-Source Income Taxed?
The most significant advantage of the Non-Dom Regime lies in the way income arising outside Greece is taxed.
Instead of being taxed on the basis of the actual amount of such income, the taxpayer pays an annual lump-sum tax of €100,000 per tax year.
The tax remains fixed, regardless of the total amount of foreign-source income earned.
Therefore, subject to the proper application of the rules governing the source of income, the regime may be particularly beneficial for individuals receiving substantial amounts of:
- Dividends from foreign companies;
- Capital gains;
- Income from international investments;
- Interest or other investment income;
- Income derived from interests in foreign corporate structures.
Payment of the lump-sum tax fully discharges the taxpayer’s Greek income tax liability in respect of foreign-source income covered by the special regime.
Furthermore, foreign-source income subject to the alternative taxation regime is not required to be declared in Greece.
What Happens to Taxes Already Paid Abroad?
A particularly important consideration in tax planning is that any tax paid abroad on income covered by the Non-Dom Regime cannot be credited against tax liabilities in Greece.
For this reason, before transferring tax residence to Greece, it is essential to assess not only the Greek tax regime but also the tax treatment of each category of income in its respective country of source.
How Is Greek-Source Income Taxed?
The Non-Dom Regime applies to foreign-source income.
Income arising in Greece remains subject to taxation under the general provisions of the Greek Income Tax Code.
The distinction between Greek-source and foreign-source income is therefore crucial and must be assessed on the basis of the nature and source of each type of income.
Can the Regime Be Extended to Family Members?
Yes. The taxpayer may request the extension of the regime under Article 5A to eligible family members.
For each family member included in the regime, an additional annual lump-sum tax of €20,000 is payable.
Eligible family members include the taxpayer’s spouse, as well as direct ascendants and descendants. Similar treatment is also provided for individuals who have entered into a registered civil partnership.
This option is particularly significant for families holding income and assets across multiple jurisdictions.
Significant Inheritance and Gift Tax Exemption for Movable Assets Located Abroad
Article 5A of the Greek Income Tax Code (AADE Decision A.1147/17.07.2026) also includes a particularly important provision for international wealth planning.
Individuals who qualify for the regime are exempt, subject to the conditions prescribed by law, from Greek inheritance and gift tax on movable assets located abroad.
Following the legislative amendments introduced in 2025, the exemption also extends to movable assets located abroad and owned by an individual subject to the regime, where such assets are transferred to a third party upon death or by way of gift.
This provision may be particularly significant in the context of international wealth and succession planning, especially for families holding substantial financial and corporate assets outside Greece.
How Long Does the Regime Apply?
The Greek Non-Dom Regime may apply for up to fifteen (15) tax years, commencing with the tax year for which the application is submitted.
The extended duration of the regime provides a significant degree of tax predictability and facilitates long-term planning of the taxpayer’s personal wealth and international investments.
When Should the Application Be Submitted?
The application for the transfer of tax residence and inclusion in the regime under Article 5A must be submitted to the competent department of the Independent Authority for Public Revenue (AADE) by 31 March of the relevant tax year.
Subject to the applicable legal requirements, individuals who have already transferred their tax residence to Greece during the immediately preceding tax year may also apply for inclusion in the regime.
The application may be submitted upon commencement of the investment or, subject to the specific conditions of the applicable regulatory framework, following its completion.
What Happens if the Investment Is Not Completed?
Compliance with the investment requirements is of particular importance.
If, upon expiry of the prescribed three-year period, it is established that the required investment has not been completed, the taxpayer’s inclusion in the regime under Article 5A may be revoked retroactively from the year of admission, resulting in the taxation of their worldwide income under the general provisions of Greek tax law.
Similarly, failure to pay the prescribed lump-sum tax in full and within the applicable deadline may result in the termination of the special tax regime.
For this reason, compliance with the regime’s requirements is not limited to the initial application stage but requires ongoing monitoring throughout the entire period of participation.
Non-Dom and International Tax Planning
Despite the apparent simplicity of the €100,000 lump-sum tax, the decision to transfer tax residence to Greece requires careful planning.
Particular consideration should be given to:
– The potential retention of tax residency in another jurisdiction;
– The applicable Double Taxation Treaties;
– The tax treatment of income in its respective countries of source;
– The ownership and management of foreign companies;
– The potential relocation of the place of effective management of corporate structures;
– Beneficial ownership rules;
– Tax and regulatory compliance obligations.
Furthermore, the source of funds and the structure of investments must be adequately documented, particularly in the context of Anti-Money Laundering (AML) and Know Your Customer (KYC) requirements, as well as the international exchange of tax information.
Who Can Benefit Most from the Regime?
The Greek Non-Dom Regime may be a particularly attractive option for:
High-Net-Worth Individuals (HNWIs) earning substantial annual income outside Greece.
International entrepreneurs and shareholders holding equity interests in companies across multiple jurisdictions.
Individuals with substantial international investment portfolios generating dividends, interest, or capital gains.
Families with cross-border wealth structures, for whom a change of tax residence forms part of broader wealth and succession planning.
However, the decision to opt for the regime should not be based solely on a comparison between the €100,000 lump-sum tax and the tax liability that would arise in Greece under the general tax provisions.
Instead, a comprehensive assessment of the individual’s overall tax position across all relevant jurisdictions is essential.
Conclusion
The Greek Non-Dom Regime has become one of the most significant instruments of Greek tax legislation for attracting high-net-worth individuals and international investors.
The combination of a fixed annual tax of €100,000 on foreign-source income, the possibility of extending the regime to family members, its 15-year duration, and the special provisions concerning movable assets located abroad creates a highly competitive framework for transferring tax residence to Greece.
However, opting for the regime is not merely a procedural change of tax residence. It requires a prior assessment of the individual’s overall wealth, corporate and tax structures, as well as coordination across the various jurisdictions in which they operate.
MAKRIS & PARTNERS LAW FIRM
MAKRIS & PARTNERS LAW FIRM advises private individuals, international investors and entrepreneurs on transferring their tax residence to Greece, qualifying for the Greek Non-Dom Regime, and the legal structuring of investments and assets in Greece.
This article is intended for general informational purposes only, based on the applicable legislative and regulatory framework, and does not constitute personalised legal or tax advice.
Antonia Ploumisti Griva-
Attorney-at-Law – ploumisti@makrispartners.com
