Since 2020 Greece has offered an alternative tax regime for high-net-worth individuals who move their tax residence to the country. Commonly described as the Greek “non-dom” regime, it is set out in Article 5A of the Income Tax Code (Law 4172/2013), introduced by Law 4646/2019. In short, a qualifying individual pays a fixed annual amount in place of income tax on foreign-source income, regardless of how much that income is.
This article summarises the conditions, the costs, the application process as recently revised by AADE, and the limits of the regime. It is general information; whether the regime is suitable depends on an individual’s full tax and personal position, including the rules of their current country of residence.
How the regime works
An individual admitted to the Article 5A regime pays a lump-sum tax of €100,000 per tax year on all income arising abroad, irrespective of its amount. On payment, the person’s Greek income tax obligations for that foreign-source income are treated as fulfilled.
The regime may be extended to family members (spouse or partner and relatives in the ascending or descending line), at an additional €20,000 per family member per year. Where the regime is extended to relatives, the Greek provisions on gift and inheritance tax do not apply to assets located abroad.
The regime lasts for a maximum of 15 tax years. Income arising in Greece remains subject to the ordinary rules of the Income Tax Code.
Conditions for admission
Under Article 5A and AADE’s published guidance, the applicant must meet the following conditions cumulatively.
1. No recent Greek tax residence
The applicant must not have been a Greek tax resident for seven of the eight years preceding the transfer of tax residence to Greece.
2. A qualifying investment of at least €500,000
The applicant, a relative, or a legal entity in which the applicant holds the majority of shares, must invest at least €500,000 in Greece, in real estate, businesses, transferable securities, or shares or interests in Greek legal persons or entities. The key points are:
- the investment must have been made on or after 12 December 2019;
- it must be completed within three years of the date of application; and
- the application must be accompanied by proof of transfer of the €500,000 to an account with a financial institution established in Greece.
Exemption for Golden Visa holders
According to AADE’s guidance, the investment condition is not required where the individual has obtained, and maintains, a residence permit for investment activity under Article 16 of Law 4251/2014 (the “Golden Visa”). This can be relevant for investors who have already acquired property under the residence-by-investment programme, although the other conditions must still be satisfied.
Applying: the 2026 procedure
AADE Decision A.1147/2026, issued on 20 July 2026, simplified the admission procedure. Applications are filed electronically through the myAADE platform (My Requests > Taxation > Alternative Income Taxation).
According to AADE’s announcement and contemporaneous professional commentary:
- an individual may apply by 30 September of the year of arrival to be covered from that year, or by 30 September of the following tax year to be covered from the year after arrival;
- supporting documents must be submitted by the deadline AADE specifies;
- an administrative tax assessment for the lump-sum amount is issued by the last working day of November; and
- the tax must be paid by the last working day of December.
The new rules apply to new applications, to pending applications, and to 2026 assessments that had not yet been paid when the decision entered into force. Because the procedural rules have been amended several times since 2020, applicants should confirm the deadlines that apply to them at the time of filing.
An applicant must also establish actual Greek tax residence under the ordinary criteria of the Income Tax Code, such as permanent or main residence, habitual abode or centre of vital interests in Greece.
Related regimes
Article 5A sits alongside two other incentives for new tax residents, which are distinct and carry their own conditions:
- Article 5B (foreign pensioners): a flat tax rate of 7% on foreign-source income, for up to 15 years.
- Article 5C (employees and freelancers): a 50% exemption from income tax on Greek-source employment or business income, for up to seven years.
These regimes cannot be combined freely, and the choice between them should be made in light of the individual’s sources of income.
Points to consider before applying
- Cost-benefit. A fixed amount of €100,000 per year is attractive only where foreign-source income is substantial. For more modest incomes, the ordinary rules or another regime may be preferable.
- Home-country rules. Leaving one’s current country of residence may trigger exit taxes, continuing residence rules or reporting obligations there. Double tax treaties and the treatment of the lump-sum tax abroad must be checked.
- Investment risk. The €500,000 investment is a genuine investment in Greek assets. Its legal and commercial merits should be assessed independently of the tax benefit, including title and planning due diligence for real estate.
- Withdrawal and loss of status. Failure to complete the investment in time, to pay the annual tax, or to maintain the conditions may lead to exclusion from the regime, with tax due under the ordinary rules.
- Changes in law. The regime rests on legislation and AADE decisions that may be amended. No outcome can be assured for the full 15-year period.
Frequently asked questions
Does the €100,000 cover Greek income as well?
No. The lump-sum tax covers foreign-source income only. Income arising in Greece, such as Greek rent or salary, is taxed under the ordinary rules.
Can the investment be made through a company?
Yes. AADE’s guidance permits the investment to be made through a legal person or entity in which the applicant holds the majority of the shares or interests, or by a relative.
Can I include my spouse and children?
Family members may be included at an additional €20,000 per person per year, subject to the conditions of the law.
Do I still need to make the €500,000 investment if I hold a Golden Visa?
According to AADE’s guidance, the investment condition does not apply to a person who has obtained and maintains a residence permit for investment activity under Article 16 of Law 4251/2014. The remaining conditions still apply.
Discussing your options
The Article 5A regime can be valuable, but it involves legal, tax and investment decisions that interact with one another. Konstantinos Tsegas & Associates Law Firm can review your circumstances in cooperation with your tax advisers and assist with the investment and the related documentation. Please contact us to arrange a consultation.