Iason Skouzos – TaxLaw

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

Angeliki Spyridon — Mon, 09 Nov 2026 13:49:24 +0000

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...

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

Angeliki Spyridon — Mon, 09 Nov 2026 13:46:18 +0000

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,...

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Taxation of rental income in Greece: individuals versus companies

Angeliki Spyridon — Mon, 09 Nov 2026 13:41:02 +0000

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...

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

Angeliki Spyridon — Mon, 09 Nov 2026 13:39:45 +0000

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...

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

Angeliki Spyridon — Mon, 09 Nov 2026 13:37:21 +0000

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...

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

Angeliki Spyridon — Mon, 09 Nov 2026 13:35:39 +0000

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%;...

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

Angeliki Spyridon — Mon, 09 Nov 2026 12:41:19 +0000

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...

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

Angeliki Spyridon — Mon, 09 Nov 2026 12:38:56 +0000

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...

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Lasting Powers of Attorney and Greek Law: Why a Greek Power of Attorney Cannot Be Relied Upon After Loss of Capacity

Angeliki Spyridon — Wed, 21 Oct 2026 12:09:16 +0000

Clients with assets in Greece increasingly ask us to prepare a power of attorney that will continue to operate if they lose mental capacity – the equivalent of an English lasting power of attorney, or a mandate of the kind recognized under the 2000 Hague Convention on the International Protection of Adults. The request is understandable: it is now standard planning in many jurisdictions. Under Greek law, however, such an instrument does not exist as a recognized category, and a Greek power of attorney drafted to survive incapacity should not be relied upon for that purpose. This article explains why....

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Fideicommissum: the Greek ‘trust’ in succession law

Angeliki Spyridon — Tue, 20 Oct 2026 13:11:15 +0000

Greek law does not recognise the common-law trust, but it offers a long-established mechanism for successive heirship – the fideicommissum (καταπίστευμα) – which the 2026 reform has preserved and refined. What it is A testator may appoint an heir but oblige that heir to hand over the estate, or a share of it, to another person – the fideicommissary – on a specified event or point in time, typically the first heir’s death (Article 1904 of the Civil Code). The first heir is a true heir for the interim period; the fideicommissary is the testator’s second, successive heir and acquires...

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