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Iason Skouzos - TaxLaw > Special topics (Page 2)

Inheritance contracts and advance renunciation: new estate planning tools under Greek law

For the first time, Greek law permits binding agreements over a future succession. Since 16 September 2026 two new instruments are available: the inheritance contract mortis causa and the advance renunciation agreement. From prohibition to planning tool Until 2026 any contract concerning the succession of a living person was void under Greek law. Law 5303/2026 lifted that prohibition, bringing Greece into line with Germany, Austria and Switzerland, where such contracts have long been part of family and business succession planning. The inheritance contract mortis causa By an inheritance contract mortis causa (κληρονομική σύμβαση αιτία θανάτου), concluded before a notary with the parties present in...

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Making a will in Greece after the 2026 reform: holographic, public and mystic wills

Law 5303/2026 rewrote the Greek law of succession from 16 September 2026. Here is what has changed for anyone making – or relying on – a will governed by Greek law. The three ordinary forms of will Greek law continues to recognise three ordinary forms of will: the holographic will (Article 1721 of the Civil Code), the public will made before a notary (Article 1725) and the mystic will, a sealed document handed to a notary (Article 1739). The former special forms of extraordinary will – military wills, wills in time of siege and wills on board ship – have been merged...

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The New Greek Inheritance Law (Law 5303/2026) – what foreign clients need to know

Greece's New Inheritance Law: 13 Practical Questions and Answers What changes for families, property owners and international clients under Law 5303/2026? Greece has introduced one of the most significant reforms of its inheritance law in decades. Law 5303/2026 modernises succession planning, introduces inheritance contracts, changes the nature of forced-heirship rights, strengthens the position of surviving spouses and substantially limits heirs' personal liability for inheritance debts. The reform is particularly relevant to internationally connected families, foreign nationals residing in Greece, and individuals owning Greek real estate or family businesses.   An important clarification for international estates Owning property in Greece does not necessarily mean that Greek inheritance...

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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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Closure of a Branch of a Foreign Commercial Company in Greece

In recent years, it has become increasingly common for foreign commercial companies to establish branches in Greece in order to carry out all or part of their activities in the country. The branch of the foreign company is managed by its legal representative, who is appointed by the foreign company, hereinafter referred to as the “mother company”. The decision concerning the appointment of the legal representative is notified to the General Commercial Registry, hereinafter referred to as the “G.E.M.I.”. In the event that the “mother company” or the foreign branch itself wishes to cease the branch’s activities and, consequently, close the branch,...

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The Schengen 90/180-Day Rule: Why Travelers Are Getting Flagged at the Border — and What to Do About It

Non-EU nationals travelling to Greece and the wider Schengen Area are subject to a well-known but frequently misunderstood limit: 90 days of stay within any rolling 180-day period. In practice, we are seeing a growing number of travelers stopped or questioned at the border because of how this rule is calculated — and because of how the EU's new digital tracking system handles it.   It's a Rolling Window, Not a Calendar Count The 90/180 rule does not reset on fixed dates. Every day a traveler is present in the Schengen Area counts toward the limit, and the 180-day "look-back" window moves with...

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Articles of Association of a Greek Société Anonyme: Mandatory Content and Room for Customisation

The incorporation of a Société Anonyme (AE) in Greece requires the drafting of Articles of Association, which must include certain elements expressly required by law, while at the same time leaving the founders considerable room to shape the company's operation according to their own needs. This article sets out in detail both the minimum mandatory content of a company's Articles of Association and the main optional provisions that may be incorporated into them, should the founders wish to do so. Minimum mandatory content Every set of Articles of Association of an AE must, at a minimum, identify the founding members of the...

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Single-Member Société Anonyme: Additional Obligations Compared to the Ordinary S.A.

A single-member (sole-shareholder) Société Anonyme (S.A.) is a special form of S.A. in which the entire share capital belongs to just one person, whether natural or legal. While it is generally subject to the same general legislative framework as an S.A. with multiple shareholders (Law 4548/2018), the law provides for certain additional publicity and documentation formalities, aimed at preventing abuse of the legal entity or sham transactions between the sole shareholder and the company. 1. Registration of single-shareholder status with the General Commercial Registry (G.E.MI.) The company must appear in its publicity records as a "Single-Member Société Anonyme" or "Sole-Shareholder S.A.," so...

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The Inheritance Contract under the New Greek Inheritance Law

One of the most significant innovations of the new Greek inheritance law is the introduction of the inheritance contract mortis causa, an institution that has not, until now, been recognized under Greek law. For the first time, the person whose estate is at issue is given the ability to regulate their succession by contract, without this doing away with the fundamental principle of freedom of disposition. The inheritance contract is a standalone institution, distinct from a will, and is governed by specific rules as regards its formation, its binding effect, and its relationship with other testamentary dispositions. Article 1798 of the...

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