Individuals who have not been tax residents of Greece for the last 7 years may choose to apply to be included for up to 15 years in the alternative taxation regime of Art. 5A of the Greek Income Tax Code concerning the tax treatment of their offshore income and potential transfers of movable assets. The regime entails the payment of an annual flat tax of € 100,000 regardless of the amount of the individual’s offshore income and the limitation of application of the standard income tax rules and rates to the Greek source income. Prior to the filing of the application, € 500,000 must be transferred to a bank account opened in Greece by the individual or a legal entity owned by the applicant by more than 50%. The amount must be invested within 3 years from the filing of the application either in real estate located in Greece or shares or bonds of legal entities established and operating in Greece.
A new law enacted last year (i.e. Art. 206 para 1-5 of L. 5222/2025) enabled the filing of the application for the extension of the regime to other family members (spouse, parents, adult descendants) not only in the year of the principal person’s own application, but also later, for the then remaining years of her inclusion in the regime. The extension entails the payment of a flat tax of € 20,000, per additional person, as settlement of the tax liability for any amount of such person’s offshore income.
Additionally, according to last year’s amendment of the regime, the extension is not required anymore for the exemption from donation or inheritance tax of offshore movable asset transfers to family members, because since last year exempt from inheritance and donation tax have become, apart from offshore movable assets located abroad and transferred to a person covered by the regime, the transfers of foreign movable assets from the person covered by the regime to any family or third person.
In addition, following an amendment passed in June this year with Art. 94 of L. 5313/2026, the requirement of having the application filed by end of March and the payment of tax made by end of July, were removed from the law and was assigned to the Independent Authority of Public Revenues (“IAPR”) to determine the relevant deadlines in a decree.
On 20.07.2026 the decree A 1147/2026 of the Governor of the IAPR was promulgated in the Government’s Gazette. For those who transferred until July 2 their tax residence to Greece the decree sets as deadline for the application to be included in the regime either September 30 of the year of relocation to Greece or September 30 of the following year. For those who transfer their tax residence to Greece in the period between July 3 and December 31, the deadline is September 30 of the following year. Payment of the tax must occur by the last working day of December.