According to the Greek Tax Law 4172 / 2013 for individuals, who wish to transfer their tax residence in Greece:

Art. 5A: Alternative taxation until 15 years, was introduced for the income of individuals, who transfer their tax residence in Greece, provided, that they make an investment in Greece.

Art. 5B: Alternative taxation was extended until 15 years, for foreign pensions’ beneficiaries, who transfer their tax residence in Greece.

Art. 5C: 50% exception from the income tax and special solidarity contribution until 7 years, was established for individuals, who transfer their tax residence provided, that they get a new job, or start a new business activity.

Art. 71H: Clear and transparent rules were adopted regarding the establishment and operation of family offices and the management of the cash - flow and family property of individuals, having tax residence in Greece.

5A FOR INVESTORS – Tax Treatment and Benefits

• Annual payment of flat-rate tax of € 100.000,00, which covers the tax liability for all foreign incomes (without obligation to be declared).

• Taxation with general provisions and obligation to declare the Greek income by submitting an annual income tax return.

• Possibility of extension to other family members by annual payment of additional flat-rate tax of € 20.000,00 per family member.

• Exemption from any inheritance tax and property donations located abroad.

• No obligation to justify the imported foreign exchange.    

5A FOR INVESTORS – Two Conditions

The individual:

• Should not have been a tax resident of Greece for the last 7 out of 8 years.
• Should prove, that he / she invests in Greece, at least, the amount of € 500.000 in real estate or companies or securities or shares or stakes in companies, based in Greece within 3 years.

or the individual should have acquired and should maintain a residence permit for investment activity in Greece (Golden Visa).

5B FOR PENSIONERS – Tax Treatment and Benefits

• Annual tax payment with 7% rate, separately for the total income, which was acquired abroad.
• Obligation to declare all income’s categories, both Greek and foreign, by submitting an annual tax income return.
• Taxation with general provisions of the domestic income (which arises in Greece).

5B FOR PENSIONERS – Three Conditions

The individual:

• Should be a beneficiary of income, earned from pension, in the foreign country.
• Should not be a tax resident in Greece for the last 5 out of 6 years.
• Should transfer his / her tax residence from a State, with which an administrative cooperation agreement, is in force, in the field of taxation in Greece.

5C FOR EMPLOYEES AND FREELANCERS – Tax Treatment and Benefits

• Exception from the income tax and special solidarity contribution for the 50% of income, earned from the salaried employment, arising in Greece, for new tax residents.
• The same tax treatment is applicable for the provision of independent services to all new tax residents, who start their business activity in Greece (freelancers or entrepreneurs).
• Annual objective expenditure is not applicable for residence and private passenger car of private use.

5C FOR EMPLOYEES AND FREELANCERS – Four Conditions

The individual:

• Should not have been a tax resident in Greece for the last 5 out of 6 years.
• Should transfer his / her tax residence from a Member State of EU or European Economic Area (ΕΕΑ), or a State, with which an administrative cooperation agreement, is in force, in the field of taxation in Greece.
• Should provide services in Greece, by working at a new position (either at a domestic legal person / entity or to a permanent establishment of a foreign entity in Greece).
• Should declare, that he / she will remain in Greece for at least 2 years.

71H FAMILY OFFICES – Conditions - Operation - Purpose

Establishment Conditions

The Family Office should:

• Employ a personnel of at least 5 persons in Greece within 12 months from its establishment.
• Annually carry out at least € 1.000.000 costs for operation.

Family Office’s Operation in Greece

In any legal form (SA / Ltd / Partnership), except from a non - profit legal entity.

Exclusive Purpose

Providing support to individuals, who are tax residents in Greece, and to their family members, while administrating and managing their assets and investments.

71H FAMILY OFFICES – Tax Treatment and Benefits

1. Specification of taxable income using OECD’s cost plus method - CPM, applying profit rate OF 7% on total expenses of any kind and their depreciations, except from the income tax.
2. All costs to which the fixed profit rate is applied, will be deducted, only if they are proven by documents, as the Greek legislation provides for.
3. Implementation of the predicted corporate tax rate 22%, from the tax year 2021 and onwards.
4. Withholding tax for the payments, which will be executed, according to general provisions.
5. VAT: the internal actions, which are performed between FO and persons, who participate in FO, as actions, which are carried out within a single entity, are outside the VAT - scope of implementation.

Source: Greek Ministry of Finance

 

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