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Tax Law

Insights – Tax issues faced by foreign persons investing in Greek commercial real estate Vol. 12 No. 5/ 2025

[vc_row triangle_shape="no"][vc_column][vc_column_text css=""] Greece’s diverse real estate market has become an increasingly attractive destination for foreign investment. The Mediterranean climate, rich cultural history, and growing economy make the country particularly appealing to investors looking for residential and commercial properties. Greece’s investment landscape is further enhanced by favorable tax incentives, such as the non-dom tax regime, the tax regime for pensioners, the tax regime for employees and, freelancers, the family office regime, and the Golden Visa program. This article provides a comprehensive overview of the tax landscape for foreign investors, investing in Greek commercial real estate. Outlining the key tax considerations at...

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5C Tax Regime – Special regime of taxation for income from employment and business activity earned in Greece by individuals who transfer their tax residence to Greece

[vc_row triangle_shape="no"][vc_column][vc_column_text css=""] Article 5C of Law 4172/2013 - Income Tax Code (“ITC”) provides for a special tax regime for income from employment and business activity earned in Greece by individuals who transfer their tax residence to Greece. Special regime of taxation The individual who will be subject to the 5C tax regime shall be exempt from income tax and special solidarity contribution of article 43A (for the tax years that was in effect) for 50% of the income from employment and business activity earned in Greece within the tax year, for a maximum period of seven (7) consecutive tax years. Moreover, the individual...

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UK to Greece Parental Cash Gifts: Greek Tax Treatment

[vc_row triangle_shape="no"][vc_column][vc_column_text css=""] Α. Parental donations/gifts The legal framework applicable to parental donations/gifts includes the provisions of Articles 53 - 115 of Law 5219/2025 which amended and codified the above Code, with effect from July 18, 2025, and onwards. Further, it should be noted that in 1966, the OECD prepared a Model Convention for the Avoidance of Double Taxation on Property, Inheritances, and Gifts. Greece has concluded agreements: on the taxation of inheritances with Germany, Spain, the USA, and Italy, and on the taxation of gifts only with Finland. Therefore, in the case of gifts, since Greece has an agreement only with Finland,...

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Practical guide to the preferential tax regimes available for individuals moving their tax residency to Greece

[vc_row triangle_shape="no"][vc_column][vc_column_text css=""] Since the end of 2019, Greece was added to the list of countries that have enacted favorable tax regimes designed to attract individuals to move their tax residence in the country.  These regimes are (i) the non-dom tax regime, (ii) the pensioner regime, and (iii) the employee and self-employed regime, known as 5A, 5B and 5C regimes respectively, as per the corresponding articles of the Income Tax Code by which they were introduced. This article provides an overview of the most important features of each of them, considering the most recent amendments and administrative interpretations since their enactment. 5A...

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Alternative taxation method for recipients of pension income who transfer their tax residency in Greece – procedure and documentation

[vc_row triangle_shape="no"][vc_column][vc_column_text css=""] Article 5B of Law 4172/2013 states that an individual who receives foreign pension (“foreign pensioner”) and who transfers their tax residence to Greece is subject to an alternative taxation method for income generated abroad. More specifically, they pay a flat rate tax for each tax year at a rate of 7% for all income (including capital gains) generated abroad. In order to join this scheme, the following conditions must be cumulatively met: the applicant must not have been tax resident in Greece in 5 out of the 6 years prior to the transfer of their tax residence to Greece...

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The “non-dom” tax regime: Alternative taxation of foreign-source income of individuals transferring their tax residence to Greece – Article 5A of the Greek Income Tax Code

[vc_row triangle_shape="no"][vc_column][vc_column_text css=""] Conditions for inclusion in the regime The provisions of article 5A of Law 4172/2013-Greek Income Tax Code (ITC) provide for an alternative tax regime, commonly known as the “non-dom regime”, according to which a taxpayer individual who transfers his or her tax residence to Greece can be taxed in an alternative manner for income generated abroad (i.e. foreign-source income) , provided all the following conditions are met: a) he or she was not tax resident in Greece during 7 out of the previous 8 years prior to transfer of his or her tax residence to Greece, which is examined based...

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Tax treatment of listed shares and stock options

1. Tax treatment of listed shares, where the seller also holds stock options The Greek law (article 42 par. 1 (b) of the Greek Income Tax Code – “ITC”) provides for an exemption from capital gains tax of 15% on the capital gains derived from the transfer of listed shares where the seller holds less than 0.5% of the listed company’s share capital. The question of whether stock options are taken into consideration for the determination of the holding percentage in order to assess the application of the tax exemption is not explicitly regulated by the Greek tax law. However, stock options, by...

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Swiss nationals: right to reside in Greece

Case study: a Swiss citizen with a spouse from a third country and minor children with Swiss nationality. Swiss nationals have the same right to reside and work in Greece as EU nationals, specifically with minimum obligations and after a very simple procedure. The same applies to their children, provided they are also Swiss nationals. In addition, in case their spouses are not Swiss nationals, but third country nationals, they will be given a residence permit to reside and work in Greece as spouses of Swiss nationals, through a little more complicated process, including some travel restrictions during the period until...

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Tax treatment of dividends and capital gains according to the DTT between Greece and Switzerland

Based on the DTT between Greece and Switzerland, the following apply in relation to dividends and capital gains taxation: Dividends (article 10) Dividends paid by a company which is a resident of Switzerland to a resident of Greece may be taxed in Greece. However, such dividends may also be taxed in Switzerland according to the laws of that State, but if the recipient is the beneficial owner of the dividends, the tax charged shall not exceed 15% of the gross amount of the dividends. This tax treatment shall not affect the taxation of the company in respect of the profits out of...

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Taxation of dividends, interest, royalties, capital gains and income from immovable property

Quick guide: Taxation of dividends, interest, royalties, capital gains and income from immovable property Tax treatment of income earned by an individual in Greece in cash or in kind in the form of dividends, interest, royalties, capital gains and income from immovable property is as follows:   i. Dividends The term “dividends” means any income derived from shares, founding titles, or other participation rights in profits that do not constitute claims from debts (liabilities), as well as income from other corporate rights, including quotas, shares, including pre-distributions and mathematical reserves, participation in profits of personal businesses, profit distributions from any type of legal...

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