12 Aug 2026

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Your Guide to Challenging Decisions of the Greek Tax Administration

[vc_row triangle_shape="no"][vc_column][vc_column_text css=""] Administrative appeal procedure Where a taxpayer disputes any decision issued against them by the Tax Administration, they must lodge an administrative appeal requesting a review of the decision within the framework of an administrative procedure by the Dispute Resolution Directorate (DED) of the Independent Authority for Public Revenue (IAPR), in accordance with the following procedure: The taxpayer submits the administrative appeal electronically via their Taxisnet account, together with the following documents: a) an application for suspension in the case of a standalone submission, The administrative appeal must be lodged with the tax authority that issued the decision within thirty (30)...

12 Aug 2026

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When Can the Sale of Investment Assets Be Treated as Business Income in Greece?

Posted by Niki Plyta

in Tax Law, Special topics

[vc_row triangle_shape="no"][vc_column][vc_column_text css=""] The Greek Income Tax Code distinguishes between income derived from investment activities and income arising from the carrying on of a business. In certain circumstances, gains realised by individuals from the disposal of assets may be treated as business income rather than capital gains. This distinction can have significant tax implications, particularly where the assets disposed of do not fall within the categories of securities specifically covered by the capital gains provisions of the Income Tax Code. The Legal Framework Article 21 of the Greek Income Tax Code provides that a "business transaction" exists where a transaction is carried out...

11 Aug 2026

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Greece Introduces Binding Tax Rulings

Posted by Niki Plyta

in Tax Law, Special topics

[vc_row triangle_shape="no"][vc_column][vc_column_text] Law 5301/2026 marks one of the most important developments in Greek tax administration in recent years by introducing, for the first time, a formal Binding Tax Ruling (BTR) procedure. Alongside this innovation, the new legislation also reforms several provisions of the Code of Tax Procedure concerning tax penalties and cash payment restrictions. The new framework is expected to enhance legal certainty for taxpayers, particularly in complex domestic and cross-border transactions, while bringing Greece closer to the practices already followed in many other OECD and EU jurisdictions. Introduction of Binding Tax Rulings The centrepiece of the new legislation is the insertion of Article 9A into...

28 May 2026

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Tax Treatment in Greece of Directors’ Fees Received from a Lithuanian Company

Posted by Angeliki Spyridon

in Tax Law, Special topics

Directors’ fees received by a Greek tax resident from participation on the board of directors of a Lithuanian company raise important cross-border tax considerations, both under the Double Tax Treaty (“DTT”) between Greece and Lithuania and under Greek domestic tax law. The analysis below assumes that the remuneration constitutes directors’ fees paid in consideration for duties performed in the capacity of a board member of the Lithuanian company, and that such remuneration does not relate to employment services or dividend distributions. Double Tax Treaty Between Greece and Lithuania The taxation of directors’ fees is governed by Article 16 of the DTT between Greece...

07 Apr 2026

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Taxation of withdrawals made by a Greek tax resident from a Self-Invested Personal Pension (SIPP) in the United Kingdom

Posted by Angeliki Spyridon

in Tax Law, Special topics

According to Articles 12(1) and (3), 14(1) and 15(4a) and (4b) of the Greek Income Tax Code: Gross income from employment and pensions includes all types of income in cash or in kind acquired in the context of an existing, past or future employment relationship. The following are considered gross income from pensions: pensions granted by the main and supplementary compulsory insurance institutions, as well as by professional funds established by law, and insurance paid as a lump sum or in the form of periodic benefits under group pension insurance contracts any other benefit received in respect of a past employment relationship. Taxable...

30 Mar 2026

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Inheritance – Taxation of assets belonging to Greek citizens located in Greece and the United States

Posted by Angeliki Spyridon

in Tax Law, Special topics

According to Article 3 of the Code of Provisions on Inheritance Tax, Gifts, Parental Benefits and Winnings from Games of Chance (Law 2961/2001 - hereinafter referred to as the "Code"), inheritance tax in Greece is levied on: Any property of any kind located in Greece, whether owned by Greek nationals or foreigners. Tangible or intangible movable property located abroad belonging to Greek nationals residing anywhere, as well as to foreign nationals residing in Greece. With regard to the Convention between Greece and the USA (Legislative Decree 2734/1953, Government Gazette A' 329/12.11.1953 – hereinafter "DTT") for the avoidance of double taxation in...

30 Mar 2026

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Taxation of director’s remuneration received by a Greek tax resident from the United Kingdom

Posted by Angeliki Spyridon

in Tax Law, Special topics

According to Articles 3, 5 and 15 of the Income Tax Code, natural persons who are tax residents in Greece are subject to tax on their taxable income derived from both Greece and abroad, i.e. on their worldwide income earned in a tax year. Income arising abroad is defined as any income that does not arise in Greece. Income from employment is considered to be of Greek origin when it is earned in Greece and of foreign origin when it is earned abroad. Income from employment is taxed in Greece according to the following scale: Income (€) ...

30 Mar 2026

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Taxation of dividends received by a Greek tax resident from the United Kingdom

Posted by Angeliki Spyridon

in Tax Law, Special topics

According to the general rules of Greek law, based on Articles 9, 36 and 40 of the Income Tax Code: If, during the tax year, a taxpayer – natural person who is a tax resident in Greece – earns income abroad, the income tax payable by that taxpayer in respect of that income is reduced by the amount of tax paid abroad on that income. The payment of the tax abroad is proven by the relevant supporting documents. The reduction in income tax provided for may not exceed the amount of tax corresponding to this income in Greece. The term "dividends"...

30 Jan 2026

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

Posted by Angeliki Spyridon

in Tax Law, Special topics

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 each stage...

21 Jan 2026

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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

Posted by Niki Plyta

in Tax Law, Special topics

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 covered by...

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