Pursuant to the non-dom tax regime enacted last year, persons who apply to become tax residents of Greece on the basis of the alternative non-dom tax regime for HNWI – which requires the person to have been non-tax resident of Greece for the last 7 years and entails exclusion of the offshore income from the income tax reporting obligations in exchange for an annual flat tax of € 100,000 – must invest at least € 500,000 in Greek assets (i.e. real estate, fixed assets of a business undertaking, securities or shareholdings). The investment can be made in the name of the applicant, an immediate relative, including the spouse, parents, grand-parents, children or grand-children, or a legal entity which is by more than 50% owned by the applicant.
The joint ministerial decree 147269/2020 (“the joint ministerial decree”) issued on 30 December 2020 by the Deputy Minister of Finance and the Alternate Minister of Growth and Investments, lays down the criteria that these investments must meet. Moreover, it supplements the decree previously issued, by setting out additional documentation which the applicant is required to submit: (i) upon his application for acquiring the non-dom tax resident status, (ii) each year until completion of the investment and (iii) each year thereafter until the regime is no longer applicable for him.
For more details, you may refer to our tax alert below: