Senior advisory in Greece since 1990

Greek tax residency is determined by a small number of objective and subjective criteria. The most straightforward is the 183-day rule: an individual who spends more than 183 days in Greece in any twelve-month period is treated as a Greek tax resident for the year in which the threshold is crossed. Presence is not the only factor; the Greek authorities also look at the individual's centre of vital interests — family, business, and economic ties.

For new arrivals, timing is decisive. Triggering Greek tax residency earlier than necessary can accelerate obligations in Greece while the prior jurisdiction still treats you as tax-resident there. Triggering it later than necessary — by maintaining obvious ties abroad — can disqualify you from the alternative regimes described below, which require a clean transfer.

We generally advise planning the move around the calendar-year boundary and documenting the exit from the prior jurisdiction. The mechanics are not difficult; the consequences of getting them wrong can be.

Greece offers three distinct regimes for qualifying individuals. Each has different conditions and different implications.

Article 5A — Non-dom regime (high-net-worth individuals). Available to individuals transferring their tax residency to Greece who commit to investing at least €500,000 in Greek real estate, Greek businesses, or qualifying securities within three years. The applicant must not have been a Greek tax resident in seven of the last eight years — a stricter prior-residence window than 5B and 5C, both of which require five-of-six. In exchange: a flat annual tax of €100,000 on worldwide non-Greek income, replacing ordinary progressive taxation. Additional family members can be added for €20,000 each. The regime applies for up to 15 years. Greek-source income continues to be taxed normally.

Article 5B — Pensioners. Available to retired individuals transferring their tax residency to Greece from any country that has a tax treaty with Greece or that exchanges information with the Greek authorities. The benefit: a flat 7% tax rate on all foreign-source income — pension, dividends, interest, royalties, capital gains, and rental income from abroad. The pension is the qualifying gateway, not the limit on coverage. The regime applies for up to 15 years. A strong option for retirees from Northern Europe, the UK, or the US.

Article 5C — Professionals and employees. Available to individuals relocating to take up employment or self-employed activity in Greece, provided they were non-resident for at least five of the last six years. The benefit: a 50% exemption on Greek-source employment and business income for seven years. Unlike 5A and 5B, the reduction applies to income actually earned in Greece — this regime is used by people who intend to work here.

The regimes are not mutually exchangeable once elected. An individual who would qualify for more than one must choose.

The Golden Visa is a residency programme, not a tax programme. Acquiring a Golden Visa through qualifying real-estate investment grants the right to reside in Greece, but it does not by itself establish Greek tax residency. If the holder spends fewer than 183 days a year in Greece and does not relocate their centre of vital interests, they remain tax-resident in their original country. The confusion is frequent and expensive; clients regularly ask us to unwind assumptions made in the wrong direction.

A separate caution applies to US citizens: under the US's citizenship-based taxation, a Greek tax-residency move under any of the special regimes does not displace ongoing US worldwide tax obligations. The Greece-US treaty mitigates double taxation but does not eliminate the US filing obligation.

There is rarely a universally right answer to "should I move my tax residency to Greece?" without looking at the individual case. For some clients the answer is yes, and the real question is when; for others, the Greek regimes are attractive on paper but the specific income profile makes them suboptimal. We advise in both directions.

If you are considering a move, we generally recommend beginning the analysis six to twelve months before the intended trigger date, so that the documentation, elections, and coordination with your current jurisdiction have time to settle.

The OECD Pillar Two framework imposes a 15% effective minimum tax on the consolidated profits of multinational groups with consolidated revenues above €750 million. Where a jurisdictional effective rate falls below 15%, a top-up tax is collected — either by the parent jurisdiction (Income Inclusion Rule), by the local jurisdiction (Qualified Domestic Minimum Top-Up Tax, QDMTT), or by a combination.

Greece has implemented a QDMTT. In practice this means that Greek subsidiaries of in-scope groups must maintain the data required to compute the GloBE ETR at the jurisdictional level and file the Greek top-up tax return, regardless of whether the ultimate parent files an IIR return elsewhere.

For finance teams, the tactical consequence is that 2025 closing data — not 2026 — drives the first Greek filings, and the reconciliation between statutory, consolidation, and GloBE perspectives needs attention well before the filing deadline.

Greece's electronic bookkeeping platform (myDATA, operated by AADE) has been phased in over several years. As of 2026, e-invoice transmission and digital bookkeeping are effectively mandatory for most businesses, and the Greek tax authority uses the data to pre-populate VAT returns and to cross-check corporate filings.

For international groups, the implication is that the Greek subsidiary's books must reconcile to myDATA in near-real-time — not just at year-end. Discrepancies between what the group ledger shows and what myDATA shows are a growing source of audit exposure. Group-level ERPs that do not natively integrate with myDATA need a bridging solution; we have helped several clients design and implement these.