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New tax provisions on individuals transferring tax residency in Greece and alternative investment funds

Reported by Ey
Jul 3, 2026· 3 min read
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Key Takeaways
  • • Greece's non-dom tax regime offers individuals transferring tax residency a flat annual tax of €100,000 on foreign-source income for up to 15 fiscal years, regardless of actual earnings abroad, with no requirement to declare foreign income.
  • • New provisions extend preferential taxation to executives managing alternative investment funds, creating an additional attraction for fund managers to relocate their tax residence to Greece.
  • • Eligibility requires non-Greek tax residency for 7 of the preceding 8 years and a minimum €500,000 investment in Greek real estate, businesses, or securities completed within three years of application.
  • • The regime allows extension to family members (spouses and relatives in ascending/descending lines) at an additional €20,000 per person annually, with inheritance, gift, and parental grant taxes waived for covered individuals.
  • • Tax paid abroad on foreign-source income covered by the alternative regime cannot be offset against Greek tax liability, and failure to pay the full lump-sum tax results in immediate termination and reversion to standard worldwide income taxation.
Summary
Greece has strengthened its competitive position for attracting high-net-worth individuals and alternative investment fund managers through enhanced non-dom tax provisions and new preferential regimes targeting fund executives. The framework, anchored in Greek law 4758/2020 and refined through subsequent amendments, establishes a straightforward alternative taxation system designed to draw foreign-sourced income earners to the country.

Under the core non-dom regime, individuals who successfully transfer their tax residency to Greece are eligible for a fixed annual tax obligation of €100,000 on all foreign-source income, irrespective of the magnitude of earnings abroad. This lump-sum approach applies for a maximum of 15 fiscal years. The regime's primary eligibility requirements are stringent: prospective applicants must demonstrate they were not Greek tax residents for at least 7 of the 8 years immediately preceding their transfer, and they must evidence a minimum €500,000 investment in Greek assets—including real estate, business interests, or transferable securities or shares—either directly or through legal entities in which they hold majority ownership. This investment must be completed within three years from the date of application submission.

A notable feature of the non-dom regime is its administrative simplicity: qualifying individuals are not required to declare income earned abroad, reducing compliance burden. However, critical limitations apply. Tax paid abroad on foreign-source income covered by the alternative regime cannot be credited or offset against Greek tax liability. Additionally, any income arising in Greece remains subject to standard Greek corporate or personal income tax provisions. Non-payment of the full lump-sum tax automatically terminates the regime, reverting the individual to standard worldwide income taxation as of that tax year forward.

The regime extends to family members, including spouses and relatives in ascending or descending lines, at an incremental cost of €20,000 per person annually. Notably, individuals covered under this extension receive exemption from inheritance, gift, and parental grant taxes. Recent extensions to the framework now encompass executives managing alternative investment funds, broadening Greece's appeal beyond traditional high-net-worth migrants to a specialized segment of investment industry professionals. These developments position Greece competitively within European tax-planning frameworks, particularly for institutional investors and fund managers evaluating jurisdictional arbitrage opportunities.

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Ey New tax provisions on individuals transferring tax residency in Greece and alternative investment funds