Greece Non-Dom Tax Regime: Article 5A and the EUR 100,000 Annual Flat Tax

Introduction: Greece's Non-Dom Regime

Greece introduced one of Europe's most competitive tax regimes for non-domiciled individuals in 2020 through Article 5A of the Greek Income Tax Code (Law 4646/2019, effective from 1 January 2020). The regime provides a flat annual tax of EUR 100,000 on all foreign-source income, regardless of amount — a fixed payment that replaces the normal progressive Greek income tax on overseas income.

This is structurally similar to Italy's Article 24-bis regime (also EUR 100,000) and the UK's former non-dom remittance basis (now abolished for most purposes). Greece entered the market for high-net-worth international residents at a time when UK non-dom planning was becoming less attractive and Italy's flat tax was already established.

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The Article 5A Regime: Core Terms

The Flat Tax

• Annual flat tax: EUR 100,000 regardless of the amount of foreign income
• Duration: up to 15 years (same as Italy's Article 24-bis)
• Scope: covers all foreign-source income — dividends, interest, capital gains, rental income, business profits — from outside Greece
• Greek-source income: taxed at normal Greek rates (progressive, up to 44%)

The mathematics: for an individual with EUR 2 million per year in foreign income, the Article 5A regime imposes EUR 100,000 of Greek tax — an effective rate of 5%. For EUR 10 million: 1%. For EUR 100,000: the regime makes no economic sense (Greek normal rates on EUR 100,000 would be lower than the EUR 100,000 flat payment).

Break-even point: the flat tax is economically beneficial if foreign income exceeds approximately EUR 250,000–350,000 per year (depending on the mix of income types and applicable normal Greek rates).

Family Extensions

Each qualifying family member (spouse, parents, children, parents-in-law, children-in-law) of the main Article 5A applicant may apply to join the regime at EUR 20,000 per person per year (reduced from EUR 20,000 for spouses initially; confirmed at EUR 20,000 for all family members in current regulations).

Example: main applicant + spouse + 2 adult children:

• Main: EUR 100,000
• Spouse: EUR 20,000
• Child 1: EUR 20,000
• Child 2: EUR 20,000
• Total family payment: EUR 160,000/year

For a family with EUR 5M in foreign income: EUR 160,000 tax vs potentially EUR 2.2M+ at normal European rates.

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Qualifying Conditions

1. Prior Tax Residency: 7 of 8 Years Test

The applicant must not have been a Greek tax resident for at least 7 of the 8 tax years preceding the application year. This prevents existing Greek residents from accessing the regime — it is designed for individuals who are new to Greek tax residency.

2. Greek Tax Residency Establishment

The applicant must transfer their tax residence to Greece. This means:

• Establishing a primary residence in Greece
• Spending sufficient time in Greece to become a Greek tax resident (183+ days, or establishing Greece as the centre of vital interests)
• Filing a Greek income tax return electing the Article 5A treatment

3. The Investment Requirement

To qualify for Article 5A, applicants must make a qualifying investment in Greece:

Investment Type	Minimum Amount
Real estate in Greece	EUR 500,000 (reduced to EUR 250,000 for investments in certain areas — see below)
Business activity or shareholding in Greek company	EUR 500,000
Greek government bonds or securities	EUR 500,000

2023 Amendment — Designated Area Reduction: From 2023, the investment threshold for real estate in non-tourist zones and low-activity areas was reduced to EUR 250,000. This effectively created a two-tier system: EUR 250,000 for low-density areas; EUR 500,000 for Athens, Thessaloniki, and popular tourist areas (Cyclades, Dodecanese islands).

The investment threshold change was partly introduced to incentivise development in less-visited regions of Greece while maintaining the minimum threshold for high-demand areas.

Application Process

1. Establish Greek tax residency (obtain AFM — Greek tax number, equivalent to the Italian Codice Fiscale)
2. File an application to join the Article 5A regime with the Greek Independent Authority for Public Revenue (AADE)
3. Pay the EUR 100,000 (or EUR 20,000 for family members) flat tax for the application year
4. AADE reviews the application and issues confirmation of regime participation

The application can be filed together with the Greek income tax return (E1 form) for the relevant year.

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The Greek Golden Visa: The Residency Foundation

What the Greek Golden Visa Provides

The Greek Golden Visa (Law 4251/2014, as amended) provides a 5-year renewable residency permit to non-EU nationals who make a qualifying investment in Greece. It does not provide citizenship — it provides residency.

Key feature: there is no minimum physical presence requirement for the Greek Golden Visa. The holder can live outside Greece and simply renew the permit every 5 years without any minimum stay obligation.

Investment Requirements (2025)

Investment Type	Threshold
Real estate in Athens, Thessaloniki, Attica region, and island municipalities over 3,100 population	EUR 400,000 (raised from EUR 250,000 in 2023)
Real estate in other areas	EUR 250,000
Conversion of commercial property to residential	EUR 250,000
Heritage building restoration	EUR 250,000
Capital investment in Greek company (shares, bonds)	EUR 400,000
Bank time deposit in Greek credit institution	EUR 400,000

The Golden Visa + Article 5A Combination

The most common structure for high-net-worth individuals targeting Greece:

1. Purchase Greek real estate meeting the Golden Visa threshold (EUR 250,000–400,000 depending on location)
2. Obtain Greek Golden Visa — 5-year residency permit; no minimum stay required
3. Elect to become Greek tax resident by spending 183+ days in Greece in a calendar year
4. Apply for Article 5A regime — EUR 100,000 flat tax on foreign income

The real estate investment serves double duty: it satisfies the Golden Visa residency requirement AND the Article 5A investment condition (EUR 250,000+ in real estate).

Combined cost for the structure:

Item	Cost
Real estate (lower area)	EUR 250,000
Real estate (Athens)	EUR 400,000
Annual Article 5A flat tax	EUR 100,000/year
Greek income tax on Greek-source income	At normal rates
Golden Visa fees (government)	EUR 2,000
Professional fees (legal, tax)	EUR 5,000–15,000

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Greek Income Tax Rates (for Reference)

Greek income is taxed at progressive rates where Article 5A does not apply:

Taxable Income	Tax Rate
Up to EUR 10,000	9%
EUR 10,001–20,000	22%
EUR 20,001–30,000	28%
EUR 30,001–40,000	36%
Over EUR 40,000	44%

This confirms why Article 5A is attractive: the effective top marginal Greek rate (44%) on high foreign income would far exceed the EUR 100,000 flat payment for most wealthy applicants.

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Path to Greek Citizenship

The path from Golden Visa residency to Greek citizenship through naturalisation:

• 7 years of legal residency in Greece (with genuine presence)
• Greek language proficiency (B1 level minimum)
• Clean criminal record
• Integration test

The 7-year citizenship path (vs Spain's 10 years) is a relative advantage. However, genuine physical presence in Greece is required for the naturalisation years — the Golden Visa's no-minimum-stay feature does not satisfy the naturalisation residency requirements.

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Comparison: Greece vs Italy Non-Dom Regimes

Feature	Greece Article 5A	Italy Article 24-bis
Annual flat tax	EUR 100,000	EUR 100,000
Duration	15 years	15 years
Family extension	EUR 20,000 per member	EUR 25,000 per member
Prior non-residency requirement	7 of 8 prior years	9 of 10 prior years
Investment requirement	EUR 250,000–500,000	None (but must establish genuine Italian tax residency)
Real estate required?	For Golden Visa route: yes	No
Path to citizenship	7 years	10 years
Dual citizenship	Generally permitted	Generally permitted
Language	Greek (B1+ for citizenship)	Italian (A2 minimum; B1+ for citizenship)
Cost of living	Lower than Italy generally	Varies by city

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Practical Living in Greece

Popular Locations for International Residents

Location	Appeal	Average Property Price
Athens (Kolonaki, Glyfada)	Capital city; culture; international schools	EUR 3,000–7,000/sqm
Thessaloniki	Second city; more affordable; vibrant culture	EUR 1,500–3,000/sqm
Mykonos / Santorini	Premium island lifestyle; international community	EUR 5,000–15,000/sqm
Crete	Large island; year-round liveable; lower cost	EUR 1,500–3,000/sqm
Rhodes	Mediterranean climate; developing international market	EUR 1,500–2,500/sqm

Healthcare

Greece has a national health system (ESY) and a well-developed private healthcare sector. Major private hospitals (Hygeia, Metropolitan, Iaso) in Athens provide international-standard care. Private health insurance is recommended for most international residents.

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HPT Group and Greece Non-Dom Advisory

HPT Group advises clients on the Greece Article 5A flat tax regime and the Golden Visa residency programme, covering real estate acquisition, Golden Visa application management, Article 5A election, and the ongoing annual compliance requirements. We work with Greek tax professionals and immigration lawyers to provide integrated advice on establishing Greek tax residency, electing the flat tax regime, and managing the interaction between Greek residency and the client's home country tax position. For clients considering the Greece + real estate combination as an alternative to Italy's flat tax, we provide a comparative analysis covering total cost, lifestyle, and path to citizenship. Contact HPT Group to discuss Greece residency and the Article 5A regime.