Last reviewed 28 October 2026 · Demetre E. Katsouris, Managing Partner
In a nutshell. Under Article 5A of the Income Tax Code, an individual who transfers tax residence to Greece and makes a qualifying investment may elect to pay a flat annual tax of €100,000 on all foreign-source income, in lieu of ordinary Greek taxation on that income, for up to fifteen years, with an additional €20,000 per year for each family member included. Greek-source income remains taxed under the ordinary rules. Since Law 5313/2026 the statutory 31 March deadline no longer applies: the application is filed by 30 September of the year of arrival where residence was transferred by 2 July, otherwise by 30 September of the following year, and the flat tax is paid by the last working day of December (decision Α.1147/2026). The regime has, since its introduction, been the principal reason a Golden Visa investor chooses to live in Greece rather than merely hold the permit.
Who qualifies?
- An individual who was not Greek tax resident in seven of the eight years preceding the transfer.
- Who invests, or has invested, at least €500,000 in Greece — in real property, in a business, in securities or in shares of Greek legal entities — within three years of the application, personally or through a relative or a controlled company; the investment condition is waived only for holders of the residence permit for investment activity under art. 16 of Law 4251/2014 — not for the property Golden Visa — although a property purchase of €500,000 or more may itself satisfy the test on its own terms.
- Who applies by 30 September and pays the flat tax in a single sum by the last working day of December each year.
What does the regime do, and not do?
Covered. All income arising outside Greece, whatever its nature and amount, is discharged by the flat payment; no obligation to declare the foreign income in detail; no Greek inheritance or gift tax on movable assets situated abroad for the duration — immovable property abroad is not covered; no foreign-tax credit is available against the flat sum.
Not covered. Income from Greek sources — rent from the Glyfada apartment, Greek employment, a Greek business — is taxed under the ordinary rules and declared in the ordinary way.
Duration. Fifteen years, revocable by the taxpayer at any time; terminated by failure to pay the annual sum.
How does it combine with property and the Golden Visa?
An investor who acquires a qualifying Golden Visa property, moves to Greece and elects the regime pays the flat tax on worldwide foreign income, ordinary Greek tax on any rent from Greek property, ENFIA, and the costs of the property; the application must be filed by 30 September of the arrival year or of the year after, depending on whether residence was transferred by 2 July, which means the move, the permit and the election are planned together. The regime also informs the choice between personal and corporate ownership of the property.
Procedure
Determination of the residence-history test; design of the qualifying investment where one is not already in place; transfer of residence and notification of the home-country authority; electronic application to the competent office with the supporting documents; the authority’s decision — the former sixty-day decision deadline was deleted by Law 5313/2026; documents are filed by 31 October and the assessment issues by the last working day of November; payment by the last working day of December; annual return for Greek-source income. The firm’s tax practice prepares the application and the firm’s accountants maintain the annual position.
Frequently asked questions
Does the €100,000 cover my spouse? A spouse or other relative is included on payment of an additional €20,000 per person per year (art. 5A(2)).
Can I leave the regime early? Yes, by revocation; thereafter ordinary rules apply.
Is a Golden Visa property sufficient as the investment? Not by reason of the permit: the statutory waiver covers only the investment-activity permit of art. 16 of Law 4251/2014. A property purchase of at least €500,000 within the three-year window may, however, satisfy the investment condition on its own terms.
Can I combine the €100,000 regime with the 50% exemption on Greek employment income? Yes, where the conditions of each article are met (tax authority FAQ on Article 5C).
What if I miss the 30 September deadline? The application may be made for the following tax year; the year missed is taxed under the ordinary rules.
This page is general information and does not constitute legal advice. It reflects the law as at the date shown and may change.
