• He or she relocates from a country with which Greece has a valid agreement concerning administrative cooperation on tax issues.
If the application for transfer of the tax residency is successful, the following rules apply to the individual:
• He or she must report in Greece all Greek-source income and all foreign-source income that is subject to this alternate tax regime.
• He or she must pay annually by the end of July a 7% flat income tax for their income obtained abroad with their tax liability in Greece for such foreign-source income being fully exhausted. A foreign tax credit is also available on certain conditions.
• He or she is subject to Greek personal income tax for all their Greek-source income according to the general tax rules.
An individual can be enrolled in this regime for a maximum period of 15 years.
Individuals taking advantage of one of the above regimes are considered tax residents of Greece for the purposes of applying the tax treaties that Greece has enacted with foreign jurisdictions.
Law 4758/4.12.2020 alternate tax status. A new special tax regime was introduced in December 2020 for foreign tax residents intending to relocate to Greece and become Greek tax residents in order to work in new employment positions or as freelancers.
Under this regime, effective for fiscal years beginning on or after 1 January 2021, individuals earning employment income in Greece who transfer their tax residence in Greece may choose to be subject to a favorable tax regime regarding their employment income for services rendered in Greece. To be eligible for this regime, an individual needs to satisfy the following conditions:
• He or she has not been a Greek tax resident for five of the last six years preceding the transfer of his or her tax residence to Greece.
• He or she relocates from a country with which Greece has a valid agreement concerning administrative cooperation on tax issues.
• He or she is providing employment services in Greece through an employment relationship as defined by Greek law to a Greek legal person or legal entity or to a Greek branch of a foreign company.
• He or she declares that his or her stay in Greece will be for at least two years.
If the application for the transfer of the tax residence per the above process is successful, the individual will be exempt from paying personal income tax on 50% of his or her Greek employment income.
An individual can be enrolled in this regime for a maximum period of seven years.
Income subject to tax. The Greek Income Tax Code (Law 4172/2013) provides for the following four categories of income:
• Employment and pension
• Business income
• Income from capital
• Capital gains income
Different tax rates apply to the categories. Some tax rates are progressive while others are exhaustive. The taxation of various types of income is described below.
Employment and pension income. Employees are subject to income tax on income derived from employment, which includes income from salaries, wages, allowances, pensions, stock-based compensation and any other payments periodically made in cash or in kind for services rendered and certain other income items.
The Greek Income Tax Code contains specific provisions for the taxation of the following types of benefits:
• Company cars, which are taxed in accordance to a deemed income formula
• Loans provided to employees, which yield deemed taxable income to the employee
• Company provided housing, regardless whether it is leased or owned by the company
• Equity-based compensation
In general, the market value of benefits in kind received by an employee or a relative of the employee is considered taxable income for the employee if the value exceeds EUR300 per year.
Other payments usually made to employees on international assignment are taxable, including the following:
• International service premiums
• Cost-of-living allowances
• Education benefits
• Relocation bonuses
• Performance bonuses
• Employee tax reimbursements
• Other allowances paid periodically and regularly
Law 5162/2024 recently introduced an exemption from taxation for payments or vouchers up to EUR5,000 per year granted by the employer to the employee to cover nursery or kindergarten costs and “newborn cash payments” of up to EUR5,000 per year, which are provided voluntarily by the employer to the employee within 12 months of the child’s birth, plus an additional EUR5,000 for each dependent child the employee has already at the time of the birth of the child. Conditions must be met for the exemption to apply. Administrative guidelines were still pending at the time of writing.
Insurance premiums paid by the employee or the employer on behalf of an employee under an insurance program and contributions made by the employee or the employer on behalf of an employee to a Voluntary Occupational Pension Fund (TEA) for health, medical or hospital coverage and/or life insurance coverage (coverage of risk of life or disability) of the employee are considered tax-exempt income for the employee up to EUR1,500 per year per employee.
Employer contributions toward a group life insurance private pension scheme or to a TEA are not considered to be employment income and are taxed separately on redemption at special final tax rates (strict conditions apply). Law 5078/2023 introduced the
following limits with effect for contributions paid in fiscal years starting from 1 January 2024:
• A maximum limit (20% cap calculated on the annual gross salary income) on the amount of insurance contributions that can be paid by the employee and the employer into TEAs and on the premiums paid by the employee and the employer on behalf of the employee in the context of group life insurance pension plans
• A maximum limit (EUR20,000 annual cap) on the amount of contributions paid into such plans for self-employed individuals
Expenses incurred by an employee in the course of their work duties does not constitute taxable income to the employee if proper tax documentation evidencing the expense exists and if it can be proven that the expenditure was a productive business expense.
Board of director fees are categorized as employment income for tax purposes but may be payable through a distribution of capital if savings exist.
The following progressive tax rate scale applies to individuals with salary income, pension income, freelancer income and personal agricultural income.
Taxable
A tax allowance may be available under certain conditions on income from salaries and pensions, which depends, on one hand, on the existence and the number of the dependent children and, on the other hand, on whether the income exceeds a certain threshold. In principle, each taxpayer with salary income, pension income, freelancer income or real estate property rental income is expected to realize expenses via electronic means of payment at a rate of 30% of their actual income per tax year. The maximum limit of the expenses is set at the amount of EUR20,000. Failure of the taxpayer to reach the corresponding limit of expenses leads to additional tax of 22% applied on the difference between the declared and the corresponding amount of expenses.
Severance payments made by Greek companies to departing employees are taxed at the following rates.
Law 5078/2023 introduced new tax rates in relation to the tax treatment of insurance payments made by an insurance company under a group life insurance pension plan and of payments made
The minimum (imputed) net income rule does not apply to the following:
• Freelancers with zero to three years of business activity (a discount is provided for years four and five)
• Profits from agricultural business activity
• Freelancers who are taxed as salaried employees based on the conditions indicated in the Greek Income Tax Code (for example, freelancers who contract with up to three physical or legal entities, and insurance intermediaries who contract with up to two insurance companies and declare their place of business as their residence)
• Persons with an 80% or higher disability
An unjustified increase of wealth of an individual is taxed as business income at a rate of 33%.
In general, an expense is considered to be deductible for business tax purposes if it satisfies the following conditions:
• The expense is incurred for the benefit of the company in the course of its usual business transactions, including company social responsibility actions.
• It corresponds to an actual transaction, and the value of the transaction is not deemed to be lower or higher than the market price of a similar transaction.
• It is recorded in the proper accounting books for the period and is evidenced by proper documentation. For social responsibility expenses, it is deductible for company profit determination purposes if the company shows profits in the year in which the expense is incurred.
Income from capital. Dividends are subject to a 5% final withholding tax rate. The concept of dividends is extended, in accordance with Organisation for Economic Co-operation and Development (OECD) guidelines, to include all distributed profits, regardless of the legal form of the distributing entity. Foreign dividends received by a Greek tax resident may be subject to more favorable tax treatment under an applicable double tax treaty.
In principle, interest is subject to a final withholding tax rate of 15%, with no further personal income tax liability for individuals.
Royalties are subject to a final withholding tax rate of 20%, with no further personal income tax liability for individuals.
Income from immovable property is subject to tax in accordance with the following progressive tax scale.
Income from immovable property is any income whether in cash or in kind that is derived from the leasing, self-use or free-use of real estate.
To derive income in kind (for example, for the owner, derived from granting the free use of the property to a third party), a 3%
rate of return is applied to the objective value of the real estate. Exemptions may apply.
Law 5073/2023 determines when the income from “short-term rental of real estate” (as defined in Law 4446/2016) is taxed as rental income and when it is taxed as business income. It provides the following with effect from 1 January 2024 for income obtained by individuals from short-term rental of real estate:
• It continues being considered and being taxed as real estate income, provided that up to two properties are rented and as long as the properties are rented furnished without the provision of any service except the provision of bed linen.
• It is considered and taxed for the first time as business income if three or more properties are rented.
Further, the law defines the maximum duration of short-term property leases in the above context.
Law 5162/2024 recently introduced a 36-month exemption from personal income tax for real estate property rental income earned by individuals for lease agreements signed between 8 September 2024 and 31 December 2025 and having a minimum three-year duration. This exemption from personal income tax applies for 36 months from the signing of the lease agreement and applies for income deriving from the rental of residences that have a surface area of up to 120 square meters and cumulatively in the previous tax years 2022 and 2023 (and 2024, if the rental takes place in 2025) have been declared on the tax return as vacant or in the 2023 tax year (or 2024 if the rental takes place in 2025) have been made available for short-term rental (such as Airbnb or similar platforms). Conditions apply.
Capital gains. Capital gains from the transfer of capital are taxed at a rate of 15%. They include gains from the transfer of securities if such transfers are not classified as business activities. For the transfer of listed shares or other listed securities, a capital gains tax is imposed only if both of the following circumstances exist:
• The listed shares or listed securities were originally acquired after 1 January 2009.
• The transferor holds a 0.5% or higher stake in the share capital of the company.
The above provisions apply to capital gains from transfers of securities taking place on or after 1 January 2014.
An exemption from capital gains tax applies to gains derived from the transfer of securities if the seller is a tax resident of a country with which Greece has entered into a double tax treaty.
Losses incurred from the sale of securities can be carried forward for a five-year period and be offset against profits that arise from the same income category.
Taxation of employer-provided stock options and stock awards. Special tax rules and rates apply with respect to the tax treatment of the following:
• Share settled stock option income
• Income deriving from stock awards, which involve the granting of shares for free as a benefit in kind in the context of stock award plans, in which the achievement of key performance
citizens are exempt from tax, provided that such donors (Greek citizens) have been residing abroad for at least 10 consecutive years and, in case of relocation to Greece, no more than five years have elapsed
• Donations of movable property located abroad that are made by a Greek citizen (donor) who has been residing outside Greece for at least 20 consecutive years and has not relocated to Greece when making the donation
The categories of rates for inheritance tax and gift tax depend on the relationship of the beneficiary to the deceased or donor. The rates are higher for more distant relatives and unrelated persons.
The following table illustrates the increase in the inheritance tax rates for categories of persons less closely related to the decedent. Tax on Tax rate on
A gift or parental grant of cash is taxed separately at a rate of 10%, 20% or 40%, depending on the relationship of the beneficiary with the provider.
Effective from 1 October 2021, parental grants or gifts to the persons belonging to Category A, as well as parental grants or the gifts of money to said persons via bank transfer, are subject to tax, which is calculated at a rate of 10%, after deducting a taxfree amount of EUR800,000.
Estate tax treaties. Greece has entered into estate tax treaties with Germany, Italy, Spain and the United States to prevent double estate taxation.
Real estate taxes. Annual Real Estate Tax (ENFIA) has replaced FAP. ENFIA is divided into a main tax and a supplementary tax. ENFIA applies to real estate located in Greece that is owned by individuals or legal entities regardless of tax residency status.
ENFIA is payable on an annual basis. The tax payable depends on a number of factors, including but not limited to the following:
• The zone price of the location where the property is located
• The area the property in square meters
• The intended use of the property
• The age of the building
• The floor where the property is located (if it is above ground)
• The number of “building facades” of the property (that is, whether the property is adjacent to a public road and if so whether it is adjacent to more than one public road)
A reduction (discount) from ENFIA may be provided on certain conditions for real estate properties that have been insured against certain risks (natural disasters and others).
In principle, the general rate of the real estate transfer tax is 3%. As a general rule, it is mandatory to effect payment of the contractual consideration exclusively using banking means of payment when concluding notarial deeds for the transfer of real
estate property against consideration, preliminary agreements and payment confirmation deeds.
A special 15% tax is applied to real estate owned by foreign companies in Greece. Many exemptions are available. In certain circumstances, actions must be taken to obtain such exemptions.
C. Social security
Coverage. The state social security system in Greece is administered by the National Social Security Organization (e-EFKA), which has encompassed the different social security organizations covering each category of employed persons. Its benefits include pensions, medical expenses and long-term disability payments.
Contributions. Social security contributions are made by employers and employees based on a percentage of the employee’s monthly salary.
Under Law 4387/2016 and subject to the relevant ministerial decisions, there are various packages in relation to social security coverage of employees, depending on the type of employment. The most common social security contribution package is set as the following:
• Employers’ contribution: 21.79%
• Employees’ contribution: 13.37%
The maximum monthly amount subject to social security contributions is now EUR7,575.62 (14 payroll periods). The percentages for monthly contributions and the ceiling on overall contributions are revised from time to time.
Totalization agreements. To provide relief from double social security taxes and to assure benefit coverage, Greece has entered into totalization agreements with the following jurisdictions.
Argentina Libya Switzerland
Australia Moldova Syria
Brazil New Zealand United States
Canada Ontario Uruguay
Egypt Quebec Venezuela
EU Member States Serbia
D. Tax filing and payment procedures
A taxpayer who is 18 or older must declare all of his or her taxable and exempt income to the tax authorities electronically.
Tax returns are filed from 15 March until 15 July of the year following the relevant calendar year.
Married persons, regardless of whether they file joint or separate tax returns, are taxed separately on all types of income.
Tax liability is determined by deducting from the computed amount of tax any previous advance payments of income tax, any taxes withheld at source and any creditable amounts of foreign taxes paid.
In addition, if the individual receives income from a business, as a general rule, 55% of the amount of a current year’s income tax must be paid as an advance payment of the following year’s tax
Consequently, a non-EU national does not need to obtain a separate work permit apart from the residence permit.
The competent authority for the issuance of a residence permit depends on the type of residence permit. For example, the Greek Ministry of Internal Affairs grants residence permits to members of boards of directors, administrators, legal representatives and higher executives of subsidiaries or branches of foreign companies exercising their commercial activities legally in Greece. Residence permits are usually valid for one year and are renewable.
In addition, individuals who have adequate means to support their activities and who are engaged in activities that make a positive contribution to the national economy may be selfemployed in Greece if they obtain an entry visa and file an application for a residence permit.
Apart from the above, residence permits are available to non-EU citizens who will invest in Greece.
In this context, a residence permit is granted to a third-country national (non-EU) who purchases real property or enters into a time-sharing agreement or lease agreement under specific requirements set by the Greek Immigration Code. The residence permit is granted for five years. The residence permit may be renewed for an equal term if the property remains in the ultimate ownership and possession of the interested party and if the party complies with other provisions of the applicable laws. The permit is granted if the interested party has been granted a visa (under certain conditions) and if the interested party has ultimate ownership and possession of the property in Greece, individually or through a legal entity of which the party is the sole owner of the respective shares or capital parts. The minimum value of the property should be EUR400,000 (or EUR800,000 for a number of geographical areas, such as Attiki/all of Athens, Mykonos, Santorini and Thessaloniki, as well as for a long list of islands with a population of more than 3,100 inhabitants).
Law 5162/2024 introduces as of 1 January 2025 a new type of residence permit, which is granted through investment in startup companies (Type B.6), provided that the prospective applicant invests a minimum of EUR250,000 in the capital of a company registered in Elevate Greece National Registry of Startups, with the purpose of acquiring shares in a share capital increase or acquiring bonds during the issuance of a bond loans.
Under the Greek Immigration Code (Law 5038/2023), a Blue Card may be issued to highly specialized personnel (European Directive 2021/1883). The Greek Immigration Code has incorporated into the Greek legal framework the provisions of the EU Intercorporate Transfer Directive (Directive 2014/66/EU) on the conditions of entry and residence of third-country nationals in the context of an intra-corporate transfer.
H. Family and personal considerations
Family members. Residence permits are granted to an EU citizen’s non-EU family members according to specific prerequisites set by the Greek Immigration Code.
Marital property regime. Spouses in Greece may choose the marital property regime they prefer. If they do not make an election, a regime of separate property applies. Spouses under a separate property regime may nonetheless acquire common property.
Before or during the marriage, the spouses may modify the default regime of separate property by entering into a marital contract adopting a community property regime. The contract must be notarized and recorded in the public registry. The community property claims purport to survive a permanent move to a non-community property country.
The property relationship of the spouses is subject, in order of priority, to the law of their last common nationality if one of them retains it, to the law of their common marital residence or to the law of the country to which they are most closely connected. These rules are fixed permanently at the time the marriage is solemnized.
Forced heirship. The Greek rules on forced heirship protect the closest relatives of the decedent, who may not disinherit them. Forced heirs are always entitled to a certain percentage of the estate, and they have all the rights and duties of other heirs. Forced heirs in general are the descendants, the parents and the surviving spouse of the decedent. If descendants survive, the parents are excluded, and the surviving spouse’s portion is one-eighth of the estate.
Forced heirs are entitled to one-half of their intestate share of the decedent’s estate. The forced heir’s right may be inherited and devolves under the rules of the intestate succession.
Any testamentary dispositions to the prejudice of the forced heir or any restrictions imposed on his or her share by the will are void. Inter vivos donations of the testator to the detriment of the estate and, consequently, to the legitimate portion are canceled if the estate at death is insufficient to provide the forced heirs their portions.
At the time of writing, it was expected that important amendments to the Greek inheritance law would be introduced in 2025 or 2026. Because of this expectation (and the possibility of the enactment of additional tax law amendments in 2025 or 2026), readers should obtain updated information.
Driver’s permits. An expatriate may drive legally in Greece on his or her home-country driver’s license. EU citizens are provided with EU driver’s licenses, which they may use for up to one year. Non-EU citizens are provided with international driver’s licenses.
No examination is required to obtain a Greek driver’s license for holders of European or international driver’s licenses.