New benefits introduced to the non-dom tax regime of Greece for High-Net-Worth-Individuals

Greece provides to individuals who become tax residents of Greece the option to not declare and tax their offshore income with the standard income tax rules but, instead, pay an annual lump sum tax of € 100,000 regardless of the amount and nature of their offshore income. The regime applies for  15 years and can be revoked through an application filed during any of these years for the then remaining period. To qualify, the individual must invest at least €  500,000 in up to three distinct investments, either in real estate or in companies located in Greece or Greek State bonds – which mature not earlier than in 3 years and are purchased via a credit institution established in Greece – or in undertakings of collective investment in transferrable securities traded on a regulated market operating in Greece or in stocks or corporate bonds of companies established in Greece, listed on a regulated market operating in Greece and traded therein. The regime also covers the minor members of the investor’s family and can be extended to the spouse and the adult members of the family for the additional annual amount of € 20,000 per person subject to the filing of a separate application for each person. With the payment of the annual € 100,000 tax and € 20,000 for each family person who opted for the regime:

1. Any income tax liability of the respective person for income from sources outside of Greece is exhausted;
2. the person does not have to disclose the origin of funds transferred to Greece;
3. the family person who has been already included in the regime is exempt from inheritance and donation tax in Greece for any assets inherited by or donated to him/her;
4. the investor becomes exempt from Greek inheritance and donation tax for movable assets transferred to him/her abroad (according to the code of taxation of inheritances and donations, no inheritance or donation tax applies, under any circumstances, to real estate properties located abroad, whereas movable assets are taxed by virtue of any of the following criteria: the Greek citizenship or residence in Greece of the beneficiary or the Greek citizenship of the donor).

With the changes introduced by a new bill which is expected to be voted at the Parliament in July 2025 and be enacted immediately thereafter, following additional benefits are introduced:

1. The application for the spouse or any other adult family member to join the regime is not required any more to be filed in the same year with the one of the main applicant. Indeed, the amendment provides the possibility to apply for any one of them in any year during which the regime remains in force for the main applicant.
2. Any movable property of the investor and the covered persons located abroad which is transferred to any person by means of inheritance or donation is excluded from inheritance/donation tax. To be noted that donations to not related persons are in general taxed more heavily, i.e at 40%, and the taxation is triggered by any of the following criteria to the extent the donation involves movable assets: the Greek citizenship or residence in Greece of the beneficiary or the Greek citizenship of the donor. With the new amendment no donation or inheritance tax shall apply to movable assets located abroad, belonging to the investor or other covered person of his family and donated to or inherited by any person.