Greek tax-resident individuals are liable to pay taxes on their global income, and non-Greek tax residents are liable to pay taxes on their income from Greek sources. Taxable income includes employment, business activity, capital and capital gains income, and is generally an aggregate of all types of income, minus income-generating expenses and applicable deductions.

Tax Deductions

Employment

Income from employment, pension and business activities is taxed at a maximum rate of 44% for income exceeding EUR60,000.

Severance payments

Special treatment applies to severance payments upon termination of employment. This applies to every lump sum severance payment that is provided by any employer, and covers any reason resulting in the termination of the employment relationship or other agreement that connects the employer with the beneficiary of the payment. The maximum tax rate in this case is 30% for severance payments exceeding EUR150,000.

Annuities

A favourable tax regime applies to annuities paid within the framework of group pension plans that are taxed at source, with the rate varying depending on the payment period. Periodically paid benefits are taxed at 15%, while lump sum payments of up to EUR40,000 are taxed at 10% and any amount above that at 20%. Tax is withheld by life insurance companies and uses up the relevant tax liability of the employee.

Capital income

Capital income is defined as income gained from dividends (taxed at 5%), interest (taxed at 15%), royalties (taxed at 20%) and real estate (taxed at 15%–45%). Gross income from rental property is automatically subject to a 3.6% digital duty on transactions (excluding residential rentals). Capital gains derived from the sale of real estate property are taxed at a flat rate of 15% of the sale price, minus acquisition costs and related expenses.

Capital gains tax for the sale of real estate property has been suspended until 31 December 2026. Moreover, Greece introduced a new tax regime for high net worth individuals, employees and pensioners who transfer their tax residence and invest in Greece, which has been included in Articles 5A, 5B and 5C of Law 4172/2013.

Tax on Income Acquired Abroad

In an effort to attract specific groups of taxpayers, Greece recently introduced three tax incentive schemes which resemble similar tax schemes that already apply in other EU countries, such as Italy.

The new initiatives currently applicable in Greece target the following:

• high net worth individual investors;
• employees and freelancers; and
• pensioners.

High net worth individuals

High net worth individuals transferring their tax residence to Greece may be subject to the alternative income taxation method for income acquired abroad, if the following requirements cumulatively apply:

• they have resided abroad for seven of the last eight years;
• the investment is higher than EUR500,000 and is in the form of real estate property, securities or shareholdings; and
• the investment was concluded within three years from the date of the application.

In accordance with the provisions of the recent tax bill submitted to the Greek parliament, high net worth individuals may file the relevant application until 31 December. The special regime terminates after 15 tax years and cannot be extended further.

High net worth individuals who meet the above conditions enjoy the following tax benefits:

• non-Greek-sourced income is tax-exempt and not reported;
• an annual flat tax liability of EUR100,000 is introduced for non-Greek-sourced income – this benefit is extended to close relatives of high net worth individuals with the payment of an additional annual tax of EUR20,000 per person;
• assets outside Greece are not subject to gift or inheritance tax; and
• no justification is required for funds remitted to Greece.

High net worth individuals must pay the annual tax until the end of the year of approval.

Employees and freelancers

The second tax regime targets employees and freelancers. Individuals wishing to transfer their tax residence to Greece may benefit from reduced income tax if the following criteria are met cumulatively:

• they have not been Greek tax residents for the last five out of six years;
• they are tax residents in an EU/EEA jurisdiction or a jurisdiction with which Greece has signed an administrative co-operation agreement;
• they will be employed by a Greek legal entity or the Greek permanent establishment of a non-Greek legal entity (unless they are self-employed); and
• they make a declaration that they will reside in Greece for at least two years.

The new tax regime applies to employees, executives (with an employment relationship), freelancers or entrepreneurs who will carry out individual business activities in Greece.

Eligible individuals may benefit from the new tax regime for a period of up to seven years and will receive a 50% tax break on their Greek-sourced income.

To register, applicants must include the jurisdiction of their tax residence in the application, and the Greek tax authorities will report the transfer of their tax residence to this jurisdiction.

Pensioners

The third initiative pertains to pensioners who wish to relocate permanently to Greece. Pursuant to the new provisions, non-Greek pensioners who decide to transfer their tax residence to Greece will be subject to a 7% flat tax for income not generated in Greece.

Those eligible for this tax incentive regime are pensioners who:

• were not Greek tax residents for the previous five out of six years; and
• have their tax residence in a jurisdiction with which Greece has signed an administrative co-operation agreement.

The tax incentive regime for pensioners does not exclude the application of the favourable provisions of double tax treaties (DTTs).

In accordance with the provisions of a recent tax bill submitted to the Greek parliament, high net worth individuals may file the relevant application until 31 December.

Taxes on Web Platforms

In an attempt to combat tax evasion from residential rentals, the State applies strict tax provisions for rentals through web platforms such as Airbnb and Tripping.

The term “short-term” leasing includes leases lasting a maximum of 60 days. The 60 days’ period applies to each lease and there are no restrictions on the number of leases permitted throughout the tax year. Moreover, new criteria are introduced for the classification of income derived from short-term leases.

Income derived from short-term leases by legal entities and persons and of three or more properties for individuals is classified as income arising from business activities.

Income earned by individuals from short-term leases of up to two properties is classified as income from immovable property.

Income from immovable property is taxed in accordance with a progressive scale from 15% up to a maximum of 45%. Income from business activities earned by individuals is taxed in accordance with a progressive scale up to a maximum of 44% and by legal persons at a flat rate of 22%. Lease payments from short-term leases classified as business activities are subject to VAT at a reduced rate of 13%.

Taxpayers failing to register their properties with the “Short-Term Real Estate Stay Registry” may face a penalty equal to 50% of the gross income of the respective tax year with a minimum amount of EUR5,000, which is doubled in the case of repetition of the infringement.

Moreover, short-term leases are subject to stayover municipality tax at the rate of 0.5% of the nightly rental and to climate crisis resilience charge, which varies depending on the time period and accommodation type.

In principle, legal entities and persons are subject to income tax at 22%, and any dividends they distribute are subject to further taxation at 5% at the level of the shareholder.

Real Estate Taxes

The imposition of various taxes on real estate acts as a disincentive to investment in immovable property. The main taxes applicable to real estate can be summarised as follows.

Unified Real Estate Tax (URET) is levied annually on property located in Greece and the tax is calculated by reference to the size, location, zone price, surface, age, use and other characteristics of the property.

An additional tax applies to individuals holding real estate property with a value exceeding EUR400,000 per property and irrespective of joint ownership. This additional tax applies to natural persons owning property of value exceeding the amount of EUR300,000. The applicable tax rates with reference to the value of the property are in the range of 0%–1%.

Over and above this additional tax, URET on individuals is further adjusted for real estate property valued at over EUR500,000, in accordance with a progressive scale ranging from 5% up to 20%.

URET is calculated on the objective minimum value of real estate, as such value is assessed by a formula of the Ministry of Finance.

The URET calculated on property owned by credit institutions and loan servicers is increased by 100%. This provision applies for the tax years 2026, 2027 and 2028. Moreover, the provision does not apply to property owned by credit institutions and loan servicers but to that leased to third parties for at least a six-month period.

Real estate tax reductions

A reduction varying from 10% up to 30% applies to real estate tax for natural persons. The main criterion for the rate of the applicable discount is the value of the real estate property, as calculated by the formula set by the Ministry of Finance. Subject to certain conditions, tax reduction is provided for residences insured by insurance companies registered with the respective registry and owned by natural persons. 

Local Real Estate Duty (TAP) is payable to municipal authorities at rates varying between 0.025% and 0.035% of the assessed value of the property.

SRET

The law provides that legal entities that have full property rights, bare ownership or usufruct property in Greece must pay an annual special property tax at 15%; the law sets out a number of exemptions related mainly to the nature of the activity of the legal persons.

Transfer tax

The prevailing real estate transfer tax rate is 3%, calculated on the taxable value of the real estate. New constructions with a building licence issued since January 2006 are subject to VAT at 24%. However, the VAT has been suspended until 31 December 2026.

Exceptionally, the acquisition of a primary residence is exempt from the payment of transfer tax if the purchaser, their spouse or a minor child is domiciled in Greece and none of them are entitled to full ownership, usufruct or habitation in a residence. These provisions apply to contracts for the purchase of property where the purchaser resides in Greece or intends to do so and falls within one of specific categories of beneficiaries.

This tax exemption is granted to an unmarried individual for the purchase of a residence of up to EUR200,000 and a land purchase of up to EUR50,000. The amount of these exemptions may be increased, depending on the individual’s marital status and number of children as well as certain other considerations. The exemption is dependent on the property not being further transferred by the buyer for a period of at least five years.

Inheritance and Gift Tax

Inheritance and gift tax are charged and regulated by the Property Tax Code, with beneficiaries of the inherited or gifted property (heirs, legatees, shareholders and any persons who acquire property through inheritance) being classified into three categories.

Assets acquired through inheritance or donation are subject to tax at a maximum rate of 10% for first-class relatives (spouse, children or grandchildren), 20% for second-class relatives (parents and siblings, then their children or grandchildren) and 40% in any other case.

The law provides for specific exemptions or special tax treatment of specified transactions.

See 1.1 Tax Regimes under Tax on Income Acquired Abroad, Capital income, Transfer tax and Inheritance and Gift Tax, and 2.6 Transfer of Assets: Vehicle and Planning Mechanisms.

See 1.1 Tax Regimes under Tax on Income Acquired Abroad, Capital income, Transfer tax and Inheritance and Gift Tax, and 2.6 Transfer of Assets: Vehicle and Planning Mechanisms.

Individuals planning to relocate to Greece should carefully plan their exit from their home jurisdiction as tax implications may arise when they exit that jurisdiction. Such exit planning should include not only federal but also state taxes, where applicable. In addition, individuals planning to relocate to Greece should first examine potential tax credits that may apply in Greece for the non-Greek-sourced income which may reduce their tax liability in Greece as well as the tax treatment in Greece of their non-Greek sourced income broadly. As exit tax is not applicable to individuals in Greece (but only to legal persons on entities), no specific tax planning is required for individuals wishing to relocate outside Greece. However, following their relocation outside Greece, the individuals may not benefit from potential tax allowances provided to Greek tax residents for their Greek-sourced income.

See 1.1 Tax Regimes under Real Estate Taxes.

The state of vulnerability that characterises the Greek economy, which is subject to permanent handicaps, makes it more difficult for business activities to develop, and in many cases exacerbates their economic difficulties. The current tax framework, especially the suspension of VAT and capital gains tax, encourages individuals and legal entities to invest in real estate.

Greece has introduced a general anti-avoidance clause into its tax system, on the basis of which the tax administration can ignore any “non-genuine” arrangement deemed to be aimed at tax avoidance or tax evasion and leading to a tax benefit for the taxpayer when assessing tax due. An arrangement is considered non-genuine if it lacks “economic or commercial essence”.

Non-Cooperative Jurisdictions and Tax Consequences

The Greek Ministry of Finance issues an annual list of jurisdictions that are deemed to be non-cooperative, and a list of jurisdictions that are deemed to have preferential tax regimes.

According to the Income Tax Law, countries with a preferential tax regime are those with a statutory corporate income tax rate lower than 60% of the Greek rate.

The tax consequences of transacting business with a resident of a non-cooperative jurisdiction or one with a preferential tax regime are as follows:

• dividends received from a subsidiary located in a non-cooperative country do not qualify for benefits under the participation exemption; and
• for the purposes of Greece’s controlled foreign company (CFC) rules, the undistributed income of a foreign legal entity will be considered as taxable income of a Greek resident that controls the foreign entity if, inter alia, the foreign entity is resident in a non-cooperative country or in a non-EU country that has a preferential tax regime.

Multilateral Competency Agreements

Greece has ratified the OECD Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information by way of Law 4428/2016 (the “Agreement”). In accordance with the Agreement, Greek financial institutions or Greek branches of international financial institutions are under an obligation to report account information regarding interest, dividends, account balances and sale proceeds from financial assets to the Ministry of Finance, and to follow certain procedures, consistent with the reporting and due diligence procedures set out in the OECD Common Reporting Standard (CRS).

Law 4378/2016 has already incorporated into domestic legislation Council Directive 2014/107 on the mandatory automatic exchange of account information between EU member state competent authorities.

EU DAC 6

Law 4714/2020 transposed into national legislation the provisions of Directive (EU) 2017/1852 (DAC 6) on tax dispute resolution mechanisms in the EU.

DAC 6 established a dedicated tax dispute resolution mechanism for the efficient resolution of cross-border tax disputes.

EU DAC 7

By way of Law 5047/2023, the Greek Parliament transposed Council Directive (EU) 2021/514, known as DAC 7, into Greek legislation. DAC 7 amends Council Directive 2011/16/EU on administrative co-operation in the field of taxation. The reporting obligation introduced by Directive 2011/16/EU is extended under DAC 7 to:

• Greek legal entities providing digital platforms to sellers for the provision of business activities and platform operators in the EU;
• platform operators that are not incorporated, managed or permanently established or resident in the EU and that make available digital platforms to sellers for performing reportable activities in Greece; and
• third parties upon request from the competent Greek authority (including platform managers, permanent establishments of non-Greek legal entities or internet service providers, etc).

The object of the reporting obligation is reportable sellers (RS), which are considered all users (whether they are individuals or entities), registered at any moment during the reportable period on the digital platform and carrying out a relevant activity against paid or credited consideration.

Specific sellers are excluded from the above obligation (excluded sellers – ES).

In the event of infringement of the foregoing obligations, the competent authority may impose a fine in the range of EUR1,000 to EUR500,000. The total amount of the fine for late submission of the seller’s data may not exceed the threshold of EUR10,000 per reportable year.

In cases of non-compliance with the obligation to submit the required information or non-cooperation during the audit, apart from the above fines and by way of joint decision, the Tax Administration may also decide to interrupt access to the non-compliant digital platforms.

UBO Register

Following the enactment of Law 4557/2018 (the “Anti-Money Laundering Law” (AMLL)), the Minister of Finance issued Ministerial Decision No 67343 ΕΞ 2019, which reduced the types of legal entities or persons that must be registered with the Central UBO Register (collectively, the “Decision”), regulating the registration procedure with the Central Ultimate Beneficial Owner Registry (the “Central UBO Register”), as set forth in Articles 20 and 21 of the AMLL.

The registration obligation concerns all corporate and other entities with a registered seat in Greece (“Incumbent Entities”) or entities engaging in any business activity that is taxable in Greece. The relevant entities must obtain and maintain accurate and updated information regarding their ultimate beneficial owners (UBOs) at a special registry kept at their premises for this purpose.

It is noted that listed companies are exempt from this requirement since they are registered automatically with the Central UBO Register through an interface between the Central Security Securities Depository and the GSIS e-platform.

All newly established entities are obliged to submit the relevant information within 60 days following their establishment. The same 60-day deadline also applies to all Incumbent Entities in the case of any future changes to their UBOs.

The information submitted to the Central UBO Register must be kept at the registered seat of the Incumbent Entity, for a time period of five years after the initial registration.

Access to the Central UBO Register for the incumbent legal entities became available on 1 November 2022 but not for general public. Access by the tax authorities, competent control authorities and competent authorities shall remain valid under the terms and conditions set by Law 4557/2018.

Greece has one of the largest numbers of small and medium-sized enterprises (SMEs) in the EU. The majority of these enterprises are family businesses, and the main shareholder is usually also the CEO or chairperson of the board, or the main partner taking the most important decisions.

The older generation generally wishes to transfer these businesses to the next generation but is often reluctant to do so and ill-equipped to prepare for the process.

The Greek State has not provided any tools to entrepreneurs for the successful transition of a family business, and it appears that large families are more concerned with the transition of their businesses to the next generation.

The trend towards globalisation has also affected Greek businesses and, again, large family businesses have proved to be better equipped to deal with the international challenges than SMEs. Their working relationships with foreign businesses and the acknowledgment that cross-border expansion entails a different legal framework for each country contribute to better preparation for a smooth business transition. However, the complexities of the tax environment and inheritance issues, such as forced heirship, generate concerns for the transition process. These concerns may be mitigated to some extent through robust tax and succession planning. Given the highly dynamic nature of the tax and inheritance law environment, the effectiveness of the relevant planning structures should be reassessed periodically over the medium term.

One of the institutions of inheritance law that determines how property passes after death is forced heirship, which aims to protect the closest relatives of the deceased and, more specifically, descendants, parents and the surviving spouse (“forced heirs”). Forced heirs are always entitled to a certain percentage of the estate despite the will of the deceased, and they have all the duties and rights of heirs.

Future spouses can enter into an agreement regulating their choice of system for the community of property and can even stipulate which assets will be included in the common property, if they so wish.

If the spouses are unable to reach an agreement, the property self-sufficiency system with a claim for participation in acquisitions will come into force.

Only when one spouse mandates the other to administer their communal assets must both spouses categorically agree that the rules of the Greek Civil Code will not come into force.

The value of transferred property must be assessed by either an independent asset valuer or the tax authorities. This valuation may be used in the future as the cost basis of the property being transferred.

There are no favourable tax provisions for the transfer of assets to the next generation that facilitate tax-free transactions. However, for assets valued at less than EUR800,000, a donation (gift) to first-class relatives (spouse, children or grandchildren) does not give rise to tax implications. Tax incentive laws governing the transformation or merger of legal persons or entities may also be used for the transition of assets from one generation to the next.

The Inheritance and Gift Tax Law (IGTL) does not regulate the taxation of digital assets or tokenised assets for the purposes of succession. Nevertheless, it appears that cryptocurrencies, such as Bitcoin, may be treated as deposits in foreign currency subject to inheritance tax, or as investments in foreign currency.

The Dispute Resolution Committee (an Administrative Committee examining the quasi-judicial recourses filed by taxpayers) held that: “income from the transfer of cryptocurrencies abroad does not fall under the provisions of the Income Tax Code that provide for, and exhaustively list, the securities from the transfer of which goodwill derives.”

Furthermore, the same Committee held, in the context of a VAT case, that the cryptocurrencies in respect of which the taxpayer stated that it provided exchange services were not legal means of payment. In this regard, any commission fees paid to the bureau de change are subject to VAT at the ordinary rate (currently 24%).

Moreover, websites or domain names may be treated as movable assets subject to inheritance tax, and their market value may be assessed by an independent valuer in order to provide supportive documentation to the tax authorities for their tax base.

By way of Law 5193/2025, the provisions supplementing Regulation (EU) 2023/1114 (the Markets in Crypto-Assets Regulation (MiCAR)) and Regulation (EU) 2023/1113 (the Transfer of Funds Regulation II (TFR II)) were introduced into domestic legislation. The enactment of Law 5193/2025 enables crypto-asset service providers to validly offer their services in Greece under MiCAR. Furthermore, by way of Decision No 245/2/02.09.2025 (Government Gazette B' 4770/08-09-2025), the Executive Committee of the Bank of Greece adopted the Guidelines of the Joint Committee of European Supervisory Authorities on templates for explanations and opinions, as well as the standardised review of crypto-assets, pursuant to Article 97(1) of Regulation (EU) 2023/1114 (JC 2024 28).

Entities that can be used for tax planning are usually charitable foundations and, in the case of inheritance, a substitution in trust, whereby a testator may impose on an heir the obligation to transfer to another beneficiary the inheritance, or a portion thereof, which the heir has acquired upon the occurrence of a specified event or at a specified time.

In general, trusts are treated as either transparent or opaque legal entities for income tax purposes, while foundations are treated as opaque legal entities. In both cases, however, it appears that the Ministry of Finance has adopted the look-through approach, treating beneficiaries as being subject to inheritance, gift or donation tax. In practice, as trusts and private foundations are not recognised in Greece, high net worth individuals usually establish a trust or private foundation outside Greece. Any distributions effected by the respective trust or private foundation are subject to income or capital tax in Greece, in accordance with the provisions of Ministerial Circular POL 1114/2017 (the “Circular”).

Although brief reference is made in Greek legislation to arrangements such as a trust or foundation, there are no provisions regulating the establishment and operation of these legal entities, and trusts are not recognised, creating impediments to family wealth planning. However, for tax purposes, specific provisions apply to income derived from trusts and foundations. To address this limitation on the use of trusts, high net worth individuals typically establish trusts in other jurisdictions and subsequently receive in Greece any proceeds distributed by those trusts. As Greek tax legislation provides guidance on the taxation of such proceeds, uncertainty regarding the applicable tax treatment is minimised.

In accordance with the Circular, a trust constitutes a particular regime for property management and settlement, which lacks any legal personality and is established either by means of a statement of will of the property owner or with the transfer of such property, in life or at death, by means of a will.

The Circular does not provide a clear definition of a trust but describes its operation and the relationship between the settlor, the trustee and the trust.

The Income Tax Code

The Income Tax Code (ITC) makes numerous references to trust and foundation structures. It defines various terms for taxation purposes and provides, inter alia, that any trust or foundation structure falls within the definition of the term legal entity (nomiki ondotita) and is therefore subject to taxation in Greece.

Trusts

Since the introduction of the ITC, trusts have been recognised for tax purposes as legal entities but not as legal persons. As a result, withholding tax applies for passive income, such as dividends, interest and royalties. Real estate income is considered business income subject to the corporate income tax rate (currently 22%).

The provisions of DTTs also apply to trusts and foundations, unless otherwise provided for by the respective DTT.

Furthermore, the Circular provides guidelines for the tax treatment of trusts and foundations from an inheritance and donation tax perspective.

Dividends, Interests and Royalties

In particular, any income from dividends, interests and royalties acquired in Greece by foreign trusts is subject to withholding tax (at 5%, 15% or 20%, as the case may be), after which their tax obligation is exhausted, to the extent that they do not have a permanent establishment in Greece.

Income from immovable property acquired in Greece is taxed as income from business activity at the tax rate of 22%.

Finally, capital gains acquired from the transfer of securities are not taxed in Greece, unless it is deemed that a foreign trust maintains a permanent establishment in Greece.

Avoiding Double Taxation

It should be noted that the foregoing provisions apply subject to the provisions of relevant DTTs. Consequently, where a trust is tax resident in a country with which Greece has concluded a DTT, the provisions of the respective DTT in force will apply; in any other case, the provisions of domestic legislation will apply.

There is no applicable information in this jurisdiction.

To the extent that there is no framework for trusts or foundations other than charitable foundations, the structures available for asset protection are fairly limited, with the most popular being the foundation. Under this structure, assets such as artworks and antiques are contributed to a foundation with a public benefit scope. Buildings can also be contributed to a foundation to be used for exhibitions or other purposes benefiting the public.

Family Offices

By way of Law 4778/2021, Greece introduced a tax incentive aimed at facilitating the management of family estates. The management of cash flows, investments and family assets of natural persons with a tax residence in Greece can be carried out by special purpose legal entities, the so-called family offices (“Family Offices”). Internal transactions between a Family Office and the persons participating in it constitute transactions carried out within a single entity and are outside the scope of VAT.

The sole objective of Family Offices is to provide support to the natural persons that reside for tax purposes in Greece and to their family members, in the administration and management of their assets and investments, held either directly or indirectly through legal persons or entities.

Family members can participate in the special purpose companies, as can legal persons or entities in which the natural persons with a tax residence in Greece and/or members of their family participate. Family Offices may also provide advisory services to trustees in relation to trusts that have been established by natural persons and their family members, as settlors, or in which such persons are beneficiaries.

The Family Office must:

• employ at least five employees in Greece within 12 months from its establishment and onwards; and
• incur operating expenses of at least EUR 500,000

The gross revenues from the services provided by Family Offices are determined by adding a percentage of profit to all their expenses and depreciations, except for income tax (ie, the cost-plus method), and their profit margin is 7%.

Guidelines on the scope and services of Family Offices

The exclusive scope of Family Offices is the administration and management of assets and investments owned, directly or indirectly, by Greek tax-resident individuals and members of their family, and includes the management of expenses incurred by them. Only family members can be shareholders, partners or members in Family Offices, either directly or through legal entities in which they are majority shareholders.

The services that they can provide include:

• services related to the personal and social life of family members, including public relations, teachers and security guards;
• management services;
• financial management services;
• strategic planning services, including business consulting, real estate planning and succession planning; and
• other consulting services, including tax consulting and legal, medical, engineering, risk management and cybersecurity services.

Special tax regime for Family Offices

Family Offices must be registered with the tax authorities.

In order for the special tax regime for Family Offices to apply, the following conditions must be cumulatively met:

• at least five employees must be employed in Greece by a Family Office within a period of 12 months from its establishment; and
• the operating expenses of a Family Office must exceed the amount of EUR1 million within the respective tax year, must be performed in Greece and must relate to its operation in Greece.

The gross revenues of Family Offices are determined on a cost-plus basis. In particular, a 7% profit margin applies to the expenses incurred by them (excluding income tax), unless the revenues registered on their books are higher than the revenues under the cost-plus basis method.

The tax and legal environment creates impediments to business succession planning strategies in most cases. Potential structures used for succession should take possible future tax implications into consideration. The structure most commonly used to transfer wealth and control through generations is the transfer of securities by way of sale or donation, depending on their value; this method of planning is effective in cases of no or very limited liability to capital gains tax.

Donations of securities are tax-exempt for amounts up to EUR150,000, after which the maximum rate is 10% for donations to first-class relatives (spouse, children or grandchildren), whereas the sale of securities incurs capital gains tax at a rate of 15%.

In some cases, the older generation contributes assets to a newly established company, shares of which are donated or transferred to the next generation. In cases where the next generation has already established a legal entity, tax incentive laws may be used for the transfer of wealth to them by way of a merger without any tax implications.

The transfer of shares between relatives is a common structure for preserving wealth and control across generations. However, it does not necessarily safeguard against potential disputes among family members. One mechanism commonly used to mitigate this risk is the preparation of a shareholders’ agreement. Such an agreement provides a framework for resolving issues that may arise among family members during the operation of the legal entity. Properly established mechanisms in the shareholders’ agreement can facilitate the efficient resolution of family disputes.

When a partial interest in an entity is transferred during lifetime or upon death, the fair market value of the interest, for transfer tax purposes, is not adjusted to reflect a discount for lack of marketability and control. For tax purposes, the value of a partial interest is its fair market value at the time of the transfer.

Increasing financial pressure on family members and dependants, as well as a greater willingness to hold executors and trustees to account for their actions, can mean a higher than usual level of complexity in disputes of this nature, with disputes relating to family and inherited wealth becoming increasingly common. Complex family structures involving second or even third families, cross-border estates that span two or more jurisdictions, and generally more valuable estates all tend to give rise to circumstances in which there is more scope for probate and will disputes, or to contentious probate.

The main mechanism in Greece for compensating aggrieved parties in wealth disputes is action before the civil courts. The rules that govern civil procedures in Greece are regulated by the Code of Civil Procedure, which provides for pre-action interim remedies, or safety measures, over and above the ordinary procedures. As an alternative, disputes may be resolved through arbitration or mediation.

In principle, damages are pecuniary, although the court may take into consideration any special circumstances and order the reinstatement of the former situation, or status quo ante.

In principle, Greek legislation does not provide for the use of corporate fiduciaries within the meaning attributed to this term in common law countries, other than in the issuance of bonds. The Bond Law (Law 3156/2003) introduced the possibility for a group of bondholders to be represented by a bondholder agent, who takes security on their behalf. The duties of the bondholder agent are performed by a trustee, which may be a credit institution or an affiliated company that legally provides services in the EEA. Unless otherwise provided for in terms of a covered bonds issue, trustees are liable to bondholders for wilful misconduct and gross negligence.

Sociétés Anonymes

The Non-Performing Loans (NPLs) Law provides for companies in the form of sociétés anonymes that may undertake the management of such loans with a licence from the Bank of Greece. Such companies may be delegated the management of claims arising from loans and/or credit agreements that have been non-performing for a period exceeding 90 days. The management of claims arising from loans and/or credits that have been performing may only be delegated together with claims against non-performing debtors.

Acting as non-beneficiary parties, management companies are entitled to file any legal remedy and to undertake any other judicial action to recover the claims under management, as well as to initiate, appear or participate in any pre-insolvency resolution, insolvency, debt settlement and special administration procedures.

As trusts and foundations are not institutions recognised by Greek legislation (with the exception of charitable foundations), such mechanisms are not applicable.

In cases where the appointment of a fiduciary is provided for by law (ie, bond loans), and unless otherwise provided for in terms of a covered bonds issue, trustees are liable to bond holders for wilful misconduct and gross negligence.

Trusts, foundations or similar entities are not authorised to own or run an active business in Greece.

Many foreign nationals of Greek descent or who identify with the Greek culture wish to acquire Greek citizenship. There are several fairly complex ways to achieve this, depending on certain characteristics of the applicant, including their status, place of birth, timing and origins.

A child born in Greece does not automatically acquire Greek citizenship, unless:

• their mother was a Greek citizen during her pregnancy and at the time of their birth;
• their father was a Greek citizen at the time of their birth; or
• both their parents were non-Greek immigrants living in Greece with a valid resident’s permit for at least five consecutive years prior to their birth.

If one of these requirements is met, the child may acquire Greek citizenship by birth, although parents can of course opt out and declare another country’s citizenship in accordance with the laws of that country.

Becoming a Greek Citizen by Going to School

A child who does not fulfil any of the prerequisites mentioned above may still acquire Greek citizenship if:

• they enrol in the first grade of a Greek primary school and are still attending when the application is filed;
• at least one of their parents had been living in Greece legally with a valid permit for at least five years prior to the child’s birth;
• at least one of the parents holds a legal resident’s card, as described in the new statute; and
• they have not reached the age of 18 years.

Alternatively, a non-Greek minor legally residing in Greece can still acquire Greek citizenship if they have attended at least nine years of primary/secondary Greek school, or six years of secondary Greek school. A non-Greek adult legally residing in Greece can acquire Greek citizenship if they have obtained a high school diploma in Greece and subsequently graduated from a higher education institution (university or technical education institution). In this case, once Greek citizenship is obtained, any underage and unmarried children automatically acquire Greek citizenship as well.

Claiming Greek Citizenship Through Ancestors

Persons born outside Greece whose parent or parents are Greek, or who have one or more Greek grandparents, are entitled to claim Greek citizenship through their ancestor(s) born in Greece.

Greek Tax Residence

Natural persons who have their permanent or principal residence or their usual abode or centre of living interests (namely their personal or financial relations) in Greece are, in principle, considered Greek tax residents.

Apart from the above factor and in compliance with the OECD Model, subject to specific exceptions, the tax residence status of a natural person is determined by their physical presence in Greece in any 12-month period. An individual that is present in Greece for a period exceeding 183 days, including short periods of living abroad, is considered a tax resident in Greece from the first day of their presence in Greece.

Notwithstanding the above, an individual’s tax-residence status is also determined on the basis of the provisions of DTTs concluded between Greece and other countries.

Greek legislation does not recognise trusts, foundations or similar entities, and the absence of these structures for efficient planning for minors or adults with disabilities renders any planning for their physical and financial care difficult.

The appointment of a guardian is provided for by the Civil Code, on the condition that neither parent has nor is able to exercise parental care. In this case, the court will appoint a guardian or entrust the exercise of parental care to a third party and determine the particulars of guardianship in accordance with the law. The following persons may be appointed as a guardian:

• a spouse;
• a physical or juristic person appointed by testamentary disposition or by a declaration; or
• the person most appropriate in the view of the court.

An adult may be placed under judicial assistance or guardianship if by reason of intellectual, psychological or physical impairment they cannot take care of themselves or their affairs or if they pose a risk to the life of their spouse, descendants or parents.

A minor who is under parental care or guardianship may be placed under judicial assistance or guardianship where the relevant conditions are fulfilled in the last year of their minority.

A court can decide whether an individual is eligible for judicial assistance. In cases of physical disability, a court will decide solely on the basis of a request filed by the disabled person concerned.

As Greece has not enacted legislation providing for the establishment of trusts or private foundations, the principal mechanisms available for planning in the event of mental incapacity are the establishment of a charitable foundation or the granting of a power of attorney prepared by a notary public. Although these mechanisms are not as efficient as the alternatives available in common law jurisdictions, they serve to safeguard the use of an individual’s funds in the event of mental incapacity. A third alternative available under Greek law is the placement of the individual under court supervision. Upon such an order being granted, a court-appointed guardian is designated to manage the property of the incapacitated person for that person’s benefit.

Public Welfare System

In Greece, the main institution by which families and individuals prepare financially for a longer lifespan is the public welfare system, which provides essential and supplementary or auxiliary protection.

Some local authorities also provide home care services, although the entitlement to and availability of these services are not always clear.

Τhe State has taken measures to increase community care services for the elderly so that they can remain in their own homes for as long as possible.

Care of Dependent Relatives

The Constitution and civil law states that the family is responsible for the care of dependent relatives of all ages, and that the State is responsible for the health of its citizens, adopting special measures for the protection of young people, the elderly and persons with disabilities, as well as providing assistance to disadvantaged members of society.

There is no insurance covering long-term care in Greece.

Some local authorities provide home-help services to elderly people requiring care. Discretionary grants and benefits are also available in some areas.

Help-at-Home Project

Many KAPI centres collaborate with the Help-at-Home project, which offers a range of services to elderly people who are unable to manage independently, such as:

• social services;
• healthcare services; and
• family assistance.

Apart from the Public Care System, the Greek State does not provide for other means that may help families and individuals prepare financially for longer lives.

According to the Greek Civil Code, a person’s relationship with their mother is established solely by birth, and that with their father is presumed from the marriage of the mother to the father, or established by means of voluntary or court-imposed acknowledgement of the child by the father.

Acknowledgment of Paternity

A father may acknowledge a child born out of wedlock as his own, provided that the mother consents. Where a mother has died or has no legal capacity to consent, the acknowledgment will be effected by the sole declaration of the father.

An acknowledgment by a father or his parents takes place by means of a declaration made before a notary public or in a last will and testament. The consent of a mother is given by means of a declaration before a notary public.

A mother has the right to demand the acknowledgement of the paternity of her child born out of wedlock through legal action directed against the father or his heirs, subject to a five-year statute of limitations starting from the child’s date of birth. The right of a child to demand acknowledgement expires one year after adulthood commences, and the rights of a father or his parents expire two years after a mother’s refusal to give consent.

Establishing Paternity

Paternity is presumed where it is established that the person against whom paternity is alleged had intercourse with the mother during the time period in which the child was conceived. Where a child is born out of wedlock, a court may, at the request of the mother, order the father whose paternity has been judicially established (even if the child is stillborn) to:

• pay expenses relating to the child’s birth; or
• provide for the maintenance of the mother, in so far as she is unable to provide for herself for the two months preceding childbirth and the four months thereafter or, in the event of special circumstances, for a maximum duration of one year.

Where paternity is voluntary or judicially acknowledged, a child is treated as having been born to married parents, including in relation to matters pertaining to the child’s family name, support and rights of inheritance.

Underage Children or Children Born Out of Wedlock

According to Article 1486, an underage child has the right to claim maintenance from its parents to the extent that the income deriving from any property the child owns or from the product of the child’s work is not sufficient to cover maintenance expenses. Maintenance is paid monthly in advance

Where a child is born out of wedlock and its paternity is highly probable, and to the extent that the mother has become impoverished, a court may order protection through the advance payment of a reasonable amount by the father to the child each month, to be set off against future maintenance payments, even before the filing of a legal action for acknowledgement of paternity.

Same-sex civil partnerships have been recognised since 2015.

Domestic partnerships are recognised in Greece, with partners enjoying the same rights available to married couples.

In 2024, Greece introduced same-sex marriage, giving to same-sex couples the right to marry under the same conditions as opposite-sex couples. Same-sex couples can also adopt children. In cases where a couple does not choose a common surname, one partner’s surname can be appended to the other’s, preserving individuality while promoting unity.

The recently enacted law of succession (Law 5303/2026, Government Gazette Bulletin A 81/22.5.2026) essentially equalises the rights of persons who have entered into a partnership agreement with those of married persons.

The recently enacted law of succession essentially equalises the rights of persons who have entered into a partnership agreement with those of married persons. For the first time, it also recognises specific inheritance rights for unmarried couples in informal cohabitation, ie, relationships without marriage or a cohabitation agreement.

The changes for these two categories are as follows.

Partners With a Partnership Agreement

• Full equalisation: the law fully equates a partner who has entered into a partnership agreement with a spouse.
• Intestate shares: the partner’s inheritance share is strengthened. Depending on the relatives left behind by the deceased, the partner inherits, immediately upon death, the prescribed percentage of the estate.
• Protection of the home: a right of exclusive use of the family home is provided for one year from the date of death.
• Abolition of restrictions: previous restrictions that limited the partner’s share in certain orders of succession are abolished.

Unmarried Couples in Informal Cohabitation

For couples who live together but have neither married nor entered into a cohabitation agreement, the new law introduces the following key provisions.

• Right to the home: the surviving partner retains the right to remain in the shared residence for one year without any payment or consideration.
• Inheritance right: the partner acquires an inheritance right in the fifth order (class) of heirs. This means that the partner inherits the entire estate if, and only if, there are no other relatives of the deceased at all, such as children, parents, siblings, uncles and aunts.
• Conditions: for this to apply, the cohabitation must be proven to have been continuous and must have lasted for more than three three years before the death. In addition, the partner is required to file an application within four months from the date of death in order to claim the inheritance.

In Greek tax law, as in other systems, there are special favourable provisions concerning the funding of charitable purposes systematically pursued by private or public institutions.

Inheritance and Donation

According to the Inheritance and Donation Code, the following gifts/donations are not subject to gift tax and do not need to be declared:

• gifts/donations of money or other movable property, whether made anonymously or not, organised at a national level and proven to be charitable in nature; and
• gifts/donations of any property to the church institutions.

Acquisitions

Acquisitions by the following legal persons and entities or individuals are also exempt from tax but not from the obligation to submit a declaration:

• the Greek State or accounts created in favour of the Greek State; and
• foreigners subject to the rule of reciprocity, on the condition that this tax exemption is provided for by international conventions – if the legislation of the foreign country does not provide for a full exemption but for lighter taxation subject to the rule of reciprocity, the inheritance or trust subject to taxation in Greece of a foreign national corporation or individual is subject to lighter taxation corresponding to the tax imposed by the foreign country in question.

Transfers of Assets

Free transfers of movable or immovable assets belonging to the State, municipalities or communities and public organisations are exempt from donation tax. By virtue of the Inheritance and Donation Code, an acquisition is also subject to independent taxation when the beneficiaries are specific legal entities.

In accordance with Article 29, paragraph 5 of that Code: “[The acquisition through inheritance of sums of money by corporations or individuals is subject to tax, which is calculated at a rate of 0.5%. The acquisition through inheritance of other assets by such individuals or corporations is subject to a tax calculated independently at a rate of 0.5%”.

The amount of the resulting tax also includes 3% in favour of municipalities and communities.

All gifts/donations of money in favour of corporations are subject to an independent tax of 0.5%, with an annual tax-free threshold of EUR1,000.

The Civil Code regulates the establishment, operation and dissolution of civil law companies (CLCs).

A minimum of two partners are required for the establishment of a not-for-profit civil law company (NPCLC), which is managed by its partners (who have joint and unlimited liability) and may appoint one or more managers. A general meeting of the partners is the supreme governing body of an NPCLC and may decide on all issues relating to its operation.

An NPCLC is not permitted to distribute profits, dividends or liquidation proceeds to its members, and upon its dissolution any liquidation proceeds will be transferred to organisations with similar purposes in accordance with the provisions of its articles of association or the decision of a general meeting.

Liability of Partners

The entry into force of Law 4072/2012 confirmed the provisions regarding the liability of the partners of a registered NPCLC, and clarified that they are held jointly and severally liable with the NPCLC for its tax liabilities. NPCLCs are subject to 22% income tax for any income received or gained.

Partners’ contributions and subscription fees, donations and aid received from enterprises and third parties are not included in the calculation of gross income. The same rules apply with regard to income from activities pursued within the framework of NGO activities.

Not-for-Profit Regulations

Another structure regulated by the Civil Code is the not-for-profit association (somatio), which is defined as a group pursuing non-profit activities made up of a minimum of 20 individuals or legal entities and having acquired a legal personality.

A somatio is established following the issuance of a court decision, and the registration of its articles of association with the competent registry is kept by the court. The general meeting is the supreme governing body of the somatio.

Unless the articles of association provide otherwise, management is exercised by a board, the members of which are elected by a general meeting of members. A somatio is liable for any acts or omissions of the persons representing it, to the extent that such acts or omissions take place in the course of the duties assigned to its representatives. The person held responsible is also jointly and severally liable with the somatio.

Members are liable to a somatio for the payment of their contributions. A somatio is wound up in accordance with the relevant terms of its articles of association, and if its number of members drops to below ten.

According to the ITC, a somatio is subject to 22% income tax only in respect of income deriving from commercial activities and is exempt from tax on income arising from the pursuits that fulfil its scope of activities.

Religious Legal Entity

The third charitable structure is the religious legal entity (RLE), which is defined as a union of at least 300 individuals belonging to the same religious community and pursuing the systematic and organised exercise of worship and collective expression of religious beliefs of its members.

It acquires legal personality upon registration with the Registry held at the Court of First Instance.

An RLE is established following the issuance of a court decision, the publication of its dogmatic principles and a summary of its articles of association or charter, and the registration of its articles of association or charter with the registry kept at the court and the RLE Registry.

An RLE is managed by its minister according to its articles of association or charter, or by a collective administrative body in which the minister must participate. An RLE is wound up in accordance with its articles of association or charter, or if the number of its members number falls below 100.

Under specific conditions, the competent authority (currently the Ministry of Education) may judicially request an RLE’s dissolution.

According to the ITC, RLEs are subject to income tax at a rate of 22% only in relation to income deriving from commercial activities.

Personal Liability of Members/Board of Directors’ Members

The members of a civil company are held jointly and severally liable with the company for both its corporate and tax liabilities. Such joint and several liability is not provided for by law for the members of a somatio or an RLE. The corporate and tax liabilities of RLEs and somatia do not impact its members, but they are liable for any acts or omissions of the persons representing it, to the extent that such act or omission takes place in the course of duties assigned to them and creates an obligation for compensation. Only the board of directors or management are held responsible for such act or omission, or liable jointly and severally with the entity.