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Holding Greek real estate through a Cyprus holding company and Greek property companies: the case for a layered structure

Quick answer For a non-resident investor acquiring one or more high-value villas in Greece for mixed personal and rental use, a structure of one Greek property company per villa, each wholly owned by a Cyprus holding company owned by the investor, is generally the most tax-efficient and flexible model. It ring-fences each asset, qualifies for exemption from the 15% Special Real Estate Tax, taxes rental profit at 22% with full expense deduction and 4% depreciation, allows input VAT recovery on a short-term rental business, repatriates profits to Cyprus free of Greek withholding tax, and preserves a tax-efficient share-sale exit for each...

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Exiting a Greek real estate investment: asset sale versus share sale

Quick answer An individual selling Greek real estate currently pays no capital gains tax: the 15% tax exists in law but its application has been suspended, at present until 31 December 2026, with an announced extension to 2030 not yet enacted. A company selling real estate pays 22% corporate income tax on the gain over the tax written-down value, and the buyer pays 3.09% transfer tax. Where the property is held in a company, the alternative is to sell the company's shares. A foreign corporate seller without a Greek permanent establishment is generally not taxed in Greece on that gain, subject...

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Taxation of rental income in Greece: individuals versus companies

Quick answer Individuals pay tax on Greek rental income on a progressive scale from 15% to 45%, with very limited deductions. Companies pay corporate income tax at a flat 22% on net profit after deducting operating expenses, financing costs and 4% annual depreciation of buildings. Rental income of an individual is reclassified as business income, taxed at 9%–44%, when three or more properties are let short-term, or when hotel-type services are provided. For a high-value property with substantial rental income and running costs, corporate ownership usually produces a lower effective tax rate. How individuals are taxed Income from leasing, owner-occupation or free use...

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The 15% Special Real Estate Tax (SRET) in Greece and how companies qualify for an exemption

Quick answer The Special Real Estate Tax (SRET) is an annual 15% tax on the value of Greek real estate owned by legal entities that do not meet transparency requirements regarding their ultimate beneficial owners. It functions as an anti-avoidance rule against the use of opaque companies, typically offshore, to hold high-value Greek property. Companies established in Greece or another EU state are exempt if their shares are registered down to the ultimate individual owners, or those individuals are disclosed, and each individual holds a Greek tax number (AFM). Properly structured holding companies therefore do not pay SRET, but the exemption...

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Dividend and interest withholding tax in Greece: the Parent-Subsidiary and Interest-Royalties Directive exemptions

Quick answer Dividends paid by a Greek company to a non-resident company are subject to 5% withholding tax. Where the recipient is an EU-resident parent company holding at least 10% for at least 24 months and meeting the other Parent-Subsidiary Directive conditions, the withholding is 0%. Interest paid by a Greek company to an associated EU company may likewise be exempt under the Interest and Royalties Directive, which requires a direct 25% shareholding held for 24 months and beneficial ownership of the interest. Both exemptions are subject to a general anti-abuse rule denying relief to non-genuine arrangements.   Dividends: the default rate A Greek...

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VAT and Digital Transaction Duty on short-term and long-term rentals in Greece

Quick answer Leasing property in Greece is VAT-exempt by default. Long-term residential leases stay exempt unless hotel-type services are provided. Short-term leases (under 60 days) by an individual stay exempt for up to two properties with no extra services; three or more properties, or any hospitality services, bring the activity into VAT at 13%. Since 1 January 2024 any company carrying on short-term rental is a VAT-registered accommodation business at 13%, whatever the number of properties or services. VAT registration adds compliance but allows recovery of input VAT on costs. Commercial leases outside VAT bear Digital Transaction Duty at 3.6%; residential...

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Buying property in Greece through a company or as an individual: steps, costs and taxes on acquisition

Quick answer The legal steps, transaction costs and acquisition taxes for buying property in Greece are the same whether the buyer is an individual or a company. A purchase is completed by notarial deed and registered at the Land Registry or Cadastre. Resale property attracts Real Estate Transfer Tax at an effective 3.09%; a new build sold by a VAT-registered developer attracts 24% VAT unless the developer has opted into the VAT suspension regime, in which case 3.09% transfer tax applies instead. The choice between personal and corporate ownership is therefore driven by what happens during the holding, rental and exit...

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Annual taxes on owning real estate in Greece: ENFIA, municipal charges and the E9 declaration

Quick answer Every owner of Greek real estate on 1 January pays ENFIA, the Unified Real Estate Ownership Tax, regardless of residence or nationality. The main tax is calculated per property from its surface area, zone value, age, floor and use. Individuals with a portfolio worth over €500,000 pay a 5%–20% surcharge on the main tax. Legal entities instead pay a supplementary tax of 5.5‰ on the total value of their property rights, reduced to 1‰ for owner-occupied business premises. Owners must also file a one-off E9 property declaration and pay municipal charges collected through electricity bills. Who pays ENFIA ENFIA is imposed...

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N.5313/2026: A New Tax Framework for carried interest and Alternative Investment Funds

Law No. 5313/2026 (Government Gazette, Issue A, No. 102 of 25 June 2026) seeks to make Greece more attractive to teams managing alternative investments. The relevant provisions address three areas: they extend the favourable tax treatment of the additional return (carried interest) to a broader range of investment structures, restore the correct cross-reference in the provision governing Alternative Investment Funds (AIFs), and extend the favourable AIF regime to third-country funds and managers. The ultimate aim is to enable fund management to be carried out from Greece without creating a taxable presence (permanent establishment) in Greece for foreign funds, while offering...

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Tax treatment of a donation of bare ownership of immovable property with retention of usufruct

With regard to usufruct of immovable property – that is, the real right of the usufructuary to use and enjoy another’s property whilst preserving its integrity – we note that it is non-transferable and extinguishes upon the death of the usufructuary. In the event that the heir acquires bare ownership of immovable property by notarial deed (such as a gift, parental gift or transfer for valuable consideration) whereby the usufruct is retained by the donor/transferor, and the donor/ usufructuary/transferor dies at a later date, bare ownership and usufruct are automatically merged, and the heir acquires the right to full ownership of...

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