Greece — offshore jurisdiction guide, tax rates and company formation by HPT Group
JurisdictionsEurope

Europe

Greece

Mediterranean EU nation with an attractive Non-Dom tax regime for foreign income.

Key Uses:Non-Dom Tax RegimeGolden VisaResidency
Greece — Mediterranean EU nation with an attractive Non-Dom tax regime for foreign income.

Greece

Mediterranean EU nation with an attractive Non-Dom tax regime for foreign income.

Overview

Greece has transformed its position as an international planning jurisdiction over the past five years, moving from a high-burden, crisis-affected economy with a difficult tax environment to one that now offers some of the most competitive inbound residency and tax programmes in Europe. The Non-Dom tax regime introduced in 2020, the Golden Visa programme providing one of Europe's most accessible residency-by-investment pathways, and a post-crisis real estate market that has delivered strong capital appreciation — combined with Greece's EU membership, Schengen travel rights, and exceptional quality of life — have made Athens, Thessaloniki, and the Greek islands increasingly prominent destinations for internationally mobile high-net-worth individuals.

Greece is fully EU and Schengen compliant, an OECD member, and participates in AEOI/CRS. Its appeal is based on legitimate, legislated tax and residency incentives rather than opacity.

Non-Dom Regime — Article 5A

Greece's non-domicile tax regime, established under Article 5A of the Greek Income Tax Code, allows qualifying individuals who transfer their tax residence to Greece to pay a flat annual tax of €100,000 on all foreign-source income, regardless of the amount of that foreign income, for a period of up to 15 years.

Key features:

  • Applicants must not have been Greek tax residents in at least 7 of the previous 8 tax years prior to the transfer of residence.
  • The €100,000 annual lump-sum payment covers all foreign-source income: foreign dividends, interest, capital gains, rental income, employment income from abroad, and other overseas income are all sheltered by the flat payment. There is no upper ceiling — whether foreign income is €1 million or €50 million in a given year, the Greek tax exposure on that foreign income remains €100,000.
  • Family members can be added to the regime for an additional €20,000 per person per year.
  • Greek-source income remains subject to standard Greek income tax rates (up to 44%) in addition to the lump-sum payment.
  • The regime does not require any minimum investment or asset threshold, though Greek residence and qualifying accommodation are required.
  • A 30% exemption applies on foreign-source dividends received by non-dom regime participants, providing additional relief on dividend income above and beyond the flat-tax shelter.

For individuals with annual foreign-source income significantly in excess of what €100,000 in tax would otherwise represent at standard rates, the Non-Dom regime offers a compelling and mathematically clear advantage. It is particularly well-suited to individuals with large investment portfolios, foreign business income, or carried interest that would otherwise attract high Greek progressive tax rates.

Golden Visa Programme

Greece's Golden Visa (Law 4251/2014 as amended) provides a 5-year renewable residency permit in exchange for a qualifying investment in Greece. It is one of the most widely subscribed residency-by-investment programmes in the EU.

Current investment thresholds (updated 2023–2024):

  • €800,000 minimum investment in real estate located in Attica (greater Athens), Thessaloniki, Mykonos, Santorini, and islands with a population above 3,100.
  • €400,000 minimum investment in real estate in all other regions of Greece.
  • Alternative qualifying routes include capital contributions to Greek companies, government bonds, and time deposits at equivalent thresholds.

The Golden Visa imposes no minimum stay requirement — holders may reside in Greece for as many or as few days as they choose while maintaining the permit. The permit provides Schengen travel rights and the right to reside and work in Greece. Immediate family members (spouse and dependent children) are included on the same permit.

After 7 years of continuous Greek legal residency, Golden Visa holders become eligible to apply for Greek citizenship, which carries full EU citizenship rights and access to a Greek passport providing visa-free or visa-on-arrival entry to 190+ countries including the United States, Canada, the UK, Japan, and Australia.

Applications are submitted through the relevant regional migration authority and the AADE (Greek tax authority) for tax registration. Processing timelines vary by region and complexity; allowing 12–24 months from application to permit receipt is prudent.

Greek Company Formation

Greek companies are formed under the Greek Companies Law. The Anonymi Etaireia (AE) is the Greek public company equivalent, requiring a minimum share capital of €25,000. The Etaireia Periorismenis Evthinis (EPE) is the private limited company form, with a minimum share capital of €4,500. The Idiotiki Kefalaiouchiki Etaireia (IKE), introduced in 2012, has a minimum share capital of just €1 and simplified governance requirements, making it the preferred vehicle for small and medium-sized businesses and startups.

Standard Greek corporate income tax is 22%. Dividend withholding tax is 5% on distributions to shareholders. VAT is charged at 24% (standard rate). Holding company and group structures with Greek elements benefit from careful analysis of Greece's general anti-avoidance rules and transfer pricing requirements administered by the AADE (Ανεξάρτητη Αρχή Δημοσίων Εσόδων).

Inheritance Tax and Succession

Greece does not levy inheritance tax between spouses and direct-line children (zero rate between Class A relatives), making it straightforward for individuals with family wealth to plan intergenerational succession without the tax friction that applies in many comparable European jurisdictions. Transfers to more distant relatives and unrelated persons are subject to rates up to 40%.

For Non-Dom regime participants, the absence of Greek inheritance tax on assets held outside Greece (combined with the flat-tax treatment of foreign income during the resident's lifetime) creates a succession-friendly environment for holding internationally diversified wealth.

Real Estate Market and Investment Returns

The Greek real estate market experienced severe price corrections during the 2010–2018 crisis period, with values in central Athens falling by 40–50% from peak. Recovery has been strong since 2019, with Athens residential and commercial property delivering consistent capital appreciation. Rental yields in central Athens are among the strongest of any major European capital, reflecting the strength of tourism-driven short-term rental demand and limited new construction supply.

For Golden Visa purchasers, the combination of qualifying investment thresholds, strong rental income potential in prime locations, and sustained capital appreciation since 2018 has made Greek real estate one of the more commercially attractive residency-by-investment propositions in Europe.

Practical Considerations

Athens and Thessaloniki have well-developed infrastructure and growing international expat communities. English is widely spoken in business, legal, and financial services contexts, and in tourism-focused areas throughout the country.

The principal retail and commercial banks are Alpha Bank, Piraeus Bank, Eurobank, and the National Bank of Greece. Opening accounts as a Golden Visa holder or new tax resident requires standard KYC/AML documentation. International private banking clients typically engage international institutions with Greek presence rather than exclusively domestic banks.

A digital nomad visa is available for remote workers with provable monthly income, providing an accessible entry point to legal residency for those not pursuing the Golden Visa or Non-Dom route.

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Our view on Greece

HPT Group has operational experience across 65+ jurisdictions. For this jurisdiction, we assess the regime on a client-specific basis — the right structure depends heavily on your existing residency, asset profile, treaty network requirements, and banking needs. Contact us for a written diagnostic memo addressing your specific situation.

HPT Group Advisory Team

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Common questions about Greece

Offshore jurisdictions offer a combination of low or zero tax on non-local income, legal frameworks designed for international structures, established English common law systems, banking infrastructure, and privacy protections. The appropriate jurisdiction depends on your specific objectives and must be selected with home-country tax and CRS obligations in mind.

Ongoing obligations typically include annual government fees, registered agent retainer, economic substance reporting (in most major offshore centres), CRS reporting if the entity is a financial account holder, and beneficial ownership register filing. In your home country, you may also have CFC disclosure, FBAR, Form 5471, or local foreign entity reporting obligations.

Bank account opening requires a complete KYC pack: certificate of incorporation, constitutional documents, register of directors and members, UBO declaration, source of funds letter, and business description. Enhanced due diligence is standard for offshore entities. HPT Group maintains introductions to private banks, EMIs, and correspondent institutions and manages the account opening process end-to-end.

The Common Reporting Standard requires financial institutions in 110+ participating jurisdictions to report account holder information to domestic tax authorities, which then share it with the account holder's country of tax residence. Your offshore accounts and entities will be reported if you are tax resident in a CRS participating country. Structures must be fully disclosed and compliant.

Simple offshore company formations complete in 3–10 business days depending on jurisdiction. Full structuring engagements — covering entity formation, banking, and a written structure memorandum — typically take 4–10 weeks. Residency applications add 4–12 weeks. Citizenship by investment takes 3–8 months. We set realistic timelines at the start of every engagement.

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