Greek “non-dom” Tax Regime

Alternative taxation for foreign individuals transferring their tax residency in Greece according to art.5A law 4172/2013 (effective from 12.12.2019)

Following several countries’ practices (i.e. Cyprus, Italy, Malta, Portugal, United Kingdom), Greece introduced a “non-domicile” tax regime for foreign individuals who wish to transfer their tax residency to Greece, by paying an annual flat tax for their income obtained abroad, regardless of the amount of such income and with no obligation to declare their foreign income in Greece.

Requirements:

  • The individual applying for the tax regime should not be a Greek tax resident for the past 7 out of 8 years, prior to the transfer of his tax residence in Greece and
  • The individual applying for the non-dom regime has to invest (under his name or under the name of a relative of his/hers or through a legal entity, the shares of which are held in majority by him/her) in Greece a minimum amount of EUR 500 000. The investment may relate to real estate, securities or shares in legal entities based in Greece and should be completed within 3 years, starting from the application date.

OR

  • The individual is subject to the Golden Visa program under the provisions of Law 4251/2014 art. 16 (in such case they are not obliged to prove their investments in Greece in order to apply for the non-dom regime).

Taxation:

  • Flat tax EUR 100 000 per annum with exhaustion of tax liability for any foreign income (with no foreign tax credit)
  • Ability to extend the scheme to family members by contributing an additional flat tax of EUR 20 000 per member per annum. Minor, unmarried children who reside with the applicable person are presumed to have the same tax residency as their parent and therefore are not burdened with the additional flat tax.
  • No obligation to declare the foreign income (or its sources) in Greece
  • Tax on any Greek-source income according to the general Greek tax provisions.

Restrictions:

  • Non-dom status may be held for a maximum of 15 years
  • The individual must submit a relevant application until March 31st before the Tax Authorities of foreign tax residents
  • The individual must provide any relevant documentation before the aforementioned Tax Authorities within 60 days from the filing
  • The country of which the individual was a tax resident before the application is informed by the Greek Tax Authorities for his application.
  • The annual flat tax (EUR 100 000 plus EUR 20 000 for any relative applying) must be paid one-off until the last working day of July. If it is not paid until December 31st (with any surcharges imposed) the applicable person loses his non-dom status and is subject to income tax in Greece for its global income according to the general Greek tax provisions.