GREECE: An Introduction to Private Wealth Law

Introduction

Greece is a Southern European country situated at the south-eastern tip of the Balkan Peninsula, bordered by the Aegean, Ionian, and Libyan Seas. In recent years, it has evolved into an increasingly attractive destination for foreign investment. A combination of a Mediterranean climate, rich cultural heritage, political stability, and a steadily expanding economy has significantly strengthened its appeal among international investors and high net worth individuals (HNWIs).

As Greece enters 2026, the country continues to grow at a steady pace, supported by strong consumer spending, increasing investment – particularly across high-growth sectors such as tourism, real estate, sustainable energy, and high-tech hub-related industries, ongoing reforms and administrative digitalisation. This positive outlook is strengthened by the largest package of tax reductions introduced in decades, designed to boost competitiveness and attract foreign capital. In this environment, the Greek tax system offers several beneficial options for HNWIs, including incentives for earning income, relocating to Greece, structuring assets, and long‑term wealth planning.

The following analysis provides a comprehensive overview of the current tax landscape in Greece, focusing on key opportunities, strategic considerations, and planning options for HNWIs seeking to optimise their tax position and investment structure.

Tax Residency

An individual is considered a tax resident of Greece if they have in Greece their permanent or principal residence, their habitual abode, or the centre of their vital interests, meaning their personal and economic ties. An individual who is present in Greece for a period exceeding 183 days in total during any twelve‑month period is also considered a tax resident of Greece from the first day of their presence in the country. As an exception to this rule, presence in Greece exclusively for touristic, medical, therapeutic, or similar private purposes does not give rise to Greek tax residency, provided that such stay does not exceed 365 days, including short interruptions abroad.

Taxation of Income

According to the general rules:

• Individuals who have their tax residence in Greece are subject to tax on their taxable income derived both within Greece and abroad – ie, their worldwide income earned in a taxable year.
• Income derived in Greece is any income from a source in Greece.

Income from employment, pensions or business activity by individuals (freelancers or sole-trader businesses) is subject to income tax in Greece as per the following tax scale from tax year 2026 onwards:

Business expenses are in principle deductible from the gross business income in order to determine the net business profit that is subject to income tax (ie, the taxable profit).

As regards the tax treatment of income earned by an individual in the tax year in Greece in cash or in kind in the form of dividends, interest, royalties, as well as income from immovable property, we note the following:

• Dividends are subject to a withholding tax of 5%.
• Interest is subject to a withholding tax of 15%.
• Royalties are subject to a withholding tax of 20%.

Income from immovable property constitutes income, whether in cash or in kind, derived from the leasing of land and real estate and it is taxed under the following progressive tax rates from tax year 2026 onwards:

Capital gains arising on the transfer of a business and of the following securities are taxed at 15%:

• non-listed shares in a company;
• listed shares and other securities, provided that the transferor holds at least 0.5% of share capital;
• shares or parts in private companies/partnerships;
• government bonds and treasury bills or corporate bonds; and
• derivative financial products.

The following are exempt from capital gains tax:

• capital gains from the transfer of listed shares and securities, provided the transferor holds less than 0.5% of share capital; and
• capital gains from Greek and EU/EEA UCITS (Mutual Funds).

Note that the taxation of income from capital gains on the transfer of immovable property has been suspended until 31/12/2026 (Article 90 of l. 5162/2024).

Non-Dom Tax Regime

Article 5A of the Greek Income Tax Code introduces an alternative taxation regime aimed at attracting non-resident HNWIs to transfer their tax residence to Greece through an alternative taxation method for foreign-sourced income. This tax incentive is structured to provide benefits, including the attraction of capital, the creation of investment units, participation in investment schemes or companies, as well as the acquisition of real estate in Greece.

If the application for inclusion of the taxable person in the alternative 5A tax regime is accepted, he/she shall pay a flat tax of EUR100,000 each tax year, irrespective of the level of income or capital gains acquired abroad. If the regime has been extended to relatives, an additional flat tax of EUR20,000 shall be paid each tax year for each relative and the provisions on the taxation of gifts, inheritances and parental grants shall not apply. For income arising in Greece, taxation is imposed in accordance with the standard Greek tax rules.

Under a recent amendment, an individual subject to the regime is exempt from inheritance or gift tax on movable property located abroad that he/she receives due to death or as a gift, respectively. Moreover, movable property located abroad that is owned by the individual and is transferred to a third party due to death or as a gift is exempt from inheritance or gift tax in Greece. The provision also applies to inheritances of decedents as of 1 January 2020.

Key tax features are outlined as follows:

• A flat tax of EUR100,000 per year exhausts the Greek tax liability on the total foreign-source income and capital gains.
• It is applicable for a maximum of 15 tax years.
• Relatives of the individual may benefit from the incentive, with an additional flat tax of EUR20,000 per year per relative.
• There is an exemption from Greek inheritance/gift tax for property located abroad.
• No foreign tax credit is granted.
• Greek-source income is taxed according to standard Greek tax rules.

Family Offices

Among the institutional reforms that have been enacted with the aim of attracting foreign investment and skilled human capital to Greece, the Greek government has also introduced the regime of “family offices”, which are special purpose companies established for the purpose of serving the wealth management needs of individuals who have their tax residence in Greece. The regime was first introduced in 2021 but has been recently (in 2025) reformed to make the framework more attractive and compatible with international practices followed for the management of family wealth.

The management of cash flows and family assets of individuals who are Greek tax residents may be carried out by family offices operating under any legal form provided by Greek law, except for non-profit legal entities.

The sole purpose of family offices is the administration and management of the assets and investments held, either directly or indirectly through legal persons or legal entities, by individuals and their family members, as well as the management of expenses incurred to cover their needs, their general living costs, and their philanthropic and cultural activities.

Under recent amendments aiming at improving the regime, Greek family offices may now also provide advisory services to trustees of trusts where the settlors or beneficiaries are family members.

For the provision of services by family offices, employees of various specialities may be engaged, or such services may be outsourced to third parties, regardless of the jurisdiction in which those third parties are established.

For the purposes of this provision, a family office must cumulatively meet the following conditions: (i) employ in Greece at least five individuals within 12 months from its incorporation and thereafter; and (ii) incur in Greece operating expenses of at least EUR500,000 annually.

The gross revenue from the services provided by family offices, which must be received through bank transfers, is determined by adding a profit margin to the total amount of all types of expenses and depreciation, excluding income tax (cost-plus method). The profit margin is set at 7%.

For determining the family office’s taxable income, the expenses on which the profit margin is calculated are deductible from its gross revenues, provided they are substantiated by appropriate supporting documents. The taxable income of the family office is subject to the corporate income tax rate (currently 22%).

Within the context of the improving features, it has been explicitly provided that the provision of services by family offices to foreign companies owned, directly or indirectly, by the individuals or their family members does not automatically constitute “exercise of effective management in Greece” (under the Place of Effective Management rules) for the purposes of determining tax residency.

Conclusion

Greece is an increasingly attractive jurisdiction for HNWIs seeking a stable, efficient, and strategically advantageous tax environment. The combination of competitive income tax reforms and alternative non‑dom regimes supports international mobility, investment optimisation, and long‑term wealth planning.

For HNWIs considering relocation in Greece, the current landscape offers a balanced combination of flexibility, predictability, and strategic advantages. With appropriate planning and professional structuring, Greece presents a continuously evolving tax environment.