Greece: A Tax Overview

In 2025, Greece introduced substantial reforms in its tax legislation. Apart from the enactment of the new Property Tax Code and the new Customs Code, significant changes have been made to the Greek Income Tax Code regarding the taxation of individuals, the special tax regimes for non-dom tax residents and family offices. Further, the Tax Authority has issued long-awaited guidelines on the digital duty on transactions and tax incentives for business transformations, summarised below.

Property Tax Code

A new Property Tax Code has been enacted under Law 5219/2025, fundamentally overhauling Greece's real estate taxation framework. The New Code unifies disparate provisions governing Single Property Tax (ENFIA), Special Property Tax (EFA), real estate transfer tax (FMA), taxation on inheritances, donations, parental benefits and taxation on gambling winnings into a single, coherent text. Interestingly, the reforms abolish obsolete provisions from prior legislation, update antiquated rules, resolve ambiguities in the old framework and align Greek property taxation with contemporary administrative standards, including digital processes. A noteworthy reform is related to the exemption from the Greek inheritance tax for Greek citizens residing abroad. Under the new legislation (enacted by Law 5222/2025, which amended Article 75 (2c) of Law 5219/2025), movable assets located outside Greece belonging to Greek citizens, who have been residing abroad for at least 5 consecutive years (instead of 10), are exempt from inheritance tax in Greece.

National Customs Code

Further, Law 5222/2025 introduces, among others, a new National Customs Code. This legislation establishes a unified and transparent framework for customs procedures, strengthens measures against tax evasion and smuggling and simplifies communication between citizens and customs authorities by updating the former National Customs Code. The new code’s principal objectives are to enhance transparency, efficiency, and compliance in cross-border trade, modernise customs procedures and align them with EU legislation. The most significant provisions of the New Code encompass enhanced digital surveillance and information exchange among customs authorities, the introduction of digital cross-border transport inspection, precise definitions of the conditions governing the operation, management and supervision of free zones, revised joint liability rules for unpaid duties and updated sanctions provisions.

Tax Rate Changes

Income tax

As of 1 January 2026, income tax rates for individuals are reduced by 2%, while a new 39% tax bracket applies to income between EUR40,001 and EUR60,000. The amended tax rates for individuals’ income from employment, pensions and business activities are as follows:

Further reductions are also applicable to intermediate income brackets from EUR10,000,01 to EUR30,000 for families with dependent children and individuals up to the age of 30. Additionally, income up to EUR20,000 is fully exempted for taxpayers with four or more dependent children or individuals up to the age of 25 (Article 15 of Law 4172/2013 (Greek Income Tax Code “ITC”), as amended by Article 3 of Law 5246/2025 & Article 15 of Law 5246/2025).

Immovable property tax rates

As from tax year 2026, income from immovable property is taxed at the following progressive rates (Article 40(3) of Greek ITC, as amended by Article 8 Law 5246/2025):

Non-Dom Tax Regime

Greece has enacted key amendments to its non-dom tax regime. Under this framework family members of the qualifying investors relocating to Greece (who invest at least EUR500,000 to Greek real estate, business, securities or shares in domestic legal entities) may now be included in the regime at any time during the initial investor's 15-year stay in Greece by paying an annual flat tax of EUR20,000 per family member (the investor pays an annual flat tax of EUR100,000 on foreign-sourced income). In addition, a tax exemption from inheritance or donation tax in Greece is now provided for the movable property of the investors, which is located abroad and consequently their heirs and donees will not be taxed on this property in Greece (Article 5A of the Greek ITC, as amended by Article 206(4), (5) of Law 5222/2025).

Moreover, Article 206(7) of Law 5222/2025 amended Article 5C of the Greek ITC, abolishing the requirement to create a new job in Greece as a prerequisite for individuals to qualify for the non-dom tax regime. This regime exempts 50% of the covered person's income from taxation for seven consecutive years, provided they were not Greek tax residents for five of the previous seven years and transfer their tax residence from an EU or EEA Member State or from a country with which Greece has an administrative cooperation agreement in the field of taxation in force.

Family Offices

Significant amendments are also set forth in relation to the operating conditions of Special Purpose Family Wealth Management Companies (Family Offices) (Article 71H of the Greek ITC, as amended by Αrticle 211 of Law 5222/2025). Key changes include:

• the reduction of the annual minimum operational expenditure threshold from EUR1,000,000 to EUR500,000;
• the expansion of the scope of activity of family offices, as beyond mere management and administration of family wealth, they are now authorised to provide advisory services to trustees of trusts in which the individuals (or their family members), whose wealth is managed under this regime, participate as settlors or beneficiaries; and
• the explicit reference that the provision of services by family offices to foreign companies owned by the covered individuals or their family members shall not constitute the exercise of their actual management or place of effective management in Greece.

Law 5162/2024

Circular 2088/2025 provides essential clarifications and guidelines to ensure the uniform application of Articles 47–56, 58 and 59 of Law 5162/2024, which introduce tax incentives for corporate transformations. Τhis Law aims to establish a uniform legislative framework for corporate transformations and applies to:

• mergers;
• divisions, including partial divisions and spin-offs;
• share exchanges; and
• company conversions, offering favourable tax treatment in each case.

However, some issues remain unresolved, such as the notion of "branch of activity." Although the Circular confirms that tax benefits apply only where the new statutory definition under Law 5162/2024 is met, it offers no explanatory criteria under which a set of assets and liabilities (or individual assets) constitute an "autonomous" business unit capable of operating independently.

Digital Duty on Transactions (“DDT”)

Circular E.2094/2025 sets forth guidelines for imposing the DDT under Law 5177/2025, which replaces Stamp Duties. The Circular clarifies the tax treatment of transactions and operations within the scope of DDT, as well as the obligations of taxpayers, including individuals, legal entities, the State and general government agencies, for the acts and transactions they carry out that are subject to DDT.

The aforesaid reforms reflect Greece’s intention to:

• boost its citizens' income;
• enhance investments;
• attract more high-net-worth individuals; and
• modernise and digitalise its tax and administrative systems in alignment with EU standards.