An Introduction to Estate Planning in Greece

Moving to Greece

Relocation to Greece has become a steadily growing trend in recent years, gaining momentum with each passing year. The country is increasingly recognised as a growing economy and an attractive hub for investment, particularly in real estate and tourism. This appeal is further enhanced by Greece’s signature Mediterranean lifestyle, making it an ever-more compelling destination for professionals and investors alike.

Why Greece?

Greece is popular for the following reasons:

• it is a member of the European Union and the Eurozone;
• it has a strategic location at the gateway between Europe, the Middle East and North Africa;
• it offers a high quality of life and Mediterranean lifestyle;
• it is a steadily developing country, offering significant investment opportunities, especially in the real estate and tourism sectors;
• it has investment-friendly policies, attracting global investors with innovative regimes; and
• it has an extensive double tax treaty network.

“Non-dom” tax regimes

The Greek Income Tax Code provides for a set of special tax incentive regimes, which have steadily gained popularity since their enactment in 2019, as they offer favourable income tax treatment, long-term tax planning and wealth structuring.

The “5A tax regime” or “foreign investor’s regime”

This flat-tax regime is tailored for foreign investors who move their tax residence to Greece and seek simplicity and certainty for their non-Greek income. To qualify, they must not have been a Greek tax resident for seven out of the last eight years prior to the transfer, and must invest at least EUR500,000 in Greece and pay a flat annual tax of EUR100,000 on all foreign-source income. This payment fully covers Greek tax liability on that income, while any income generated in Greece is taxed at standard Greek rates.

On top of that, individuals under this regime enjoy full Greek inheritance and gift tax exemption on foreign assets they receive or transfer to others. The regime lasts 15 years, although participants can opt out at any time. Close family members can also join, with an extra annual tax of EUR20,000 per person.

Please note that individuals from third countries (ie, non-EU nationals) may also qualify for a Golden Visa through the same investment, provided that the specific conditions set out in the relevant residence permit legislation are met.

The “5B tax regime” or “foreign pensioner’s regime”

This regime is suitable for retirees who receive a pension from abroad (ie, outside of Greece) and seek a low, flat tax rate on their foreign-source income, long-term certainty and a high quality of life within the EU. To qualify, applicants must not have been Greek tax residents for five of the six years prior to the transfer, and must receive a foreign pension from social security institutions or group pension plans. In addition, their last tax residence must be in a country that co-operates with Greece on tax matters.

Under the regime, participants pay 7% tax on foreign-source income, while income generated in Greece is subject to standard Greek tax rates. The regime lasts 15 years, but it cannot be extended to family members, who must each apply separately.

The “5C tax regime” or “50% tax break regime”

This regime is designed for employees and self-employed professionals moving to Greece, and offers a 50% tax exemption on Greek employment or professional income. It is particularly attractive for executives, specialists and entrepreneurs looking to relocate. To qualify, applicants must not have been Greek tax residents for five of the six years prior to the move. Their last tax resident must be in an EU or EEA country or in a state that co-operates with Greece on tax matters. Finally, they must provide services in Greece for a Greek employer or as a self-employed professional and commit to residing in Greece for at least two years. The regime lasts seven years, providing a clear window of tax relief for newcomers.

As the 5C regime is linked to employment/working in Greece, third-country nationals must hold a residence permit that grants the right to work in the country (a Golden Visa does not confer working rights).

Why succession and estate planning are important in Greece

Succession planning in Greece is moving towards a broader family wealth continuity strategy, driven by the following three main practical realities.

• Asset fragmentation remains a recurring issue for families with more than one heir and more than one material asset (eg, a family home alongside a second residential or commercial property, shares in a family business or cash/cash equivalent portfolio). Under the inheritance law rules, in the absence of a will, heirs end up in joint ownership structures that create difficulties in asset exploitation and enjoyment and – most importantly – are the source of significant interfamily frictions and disputes going forward. This becomes even more serious in the case of family business shares, where an inherited business requires uninterrupted decision-making and a clear control model. A reform agenda is currently under the final stages of consideration, with inheritance law legislation recently launched by the Hellenic Ministry of Justice identifying these matters of concern and framing key changes as tools to prevent the “splitting” of inherited assets or businesses.
• The speed and certainty of the first estate administration steps are becoming a central private wealth concern. Greece has already implemented a major procedural modernisation: the publication of wills (holographic, sealed and public) is routed through a digital workflow and handled by notaries via an electronic portal (diathikes.gr), with the stated goal of taking tens of thousands of cases out of the courts and compressing timelines from several months to just a few business days.
• There is a clear market shift toward governance solutions that reduce disputes and preserve value across generations. This includes the increasing relevance of trust and foundation-based structures where appropriate, particularly for governance, the protection of minors and vulnerable beneficiaries, and asset protection objectives within the limits of Greek law and family office arrangements as “operating platforms” for co-ordinated family wealth management.

Against this background, the trend in Greece is shifting away from reactive, post-death problem-solving towards proactive planning, with clear testamentary documentation, governance design (especially for business families) and structures that reduce fragmentation and uncertainty at the moment of transition.

Commonly used succession planning mechanisms

Wills

The will remains the traditional and most commonly used succession planning instrument in Greece. Increasingly, wills are treated as operational instruments designed to prevent the typical failure modes that arise after death (fragmentation of assets, ambiguity, and involuntary co-ownership disputes).

Two features of Greek succession law make early planning particularly critical:

• forced heirship (reserved portion), under which descendants, parents and the surviving spouse or registered partner who would inherit intestate are entitled to a share generally equal to half of their intestate entitlement; and
• estate debt exposure, as heirs may be liable for estate obligations unless acceptance is carefully structured.

Accordingly, will drafting should focus on avoiding unintended co-ownership of key assets, ensuring clarity as to who inherits what, when and under what conditions, and creating an implementable distribution plan supported by accurate asset mapping and consistent ownership documentation.

From 1 November 2025, the publication of wills for deaths occurring after that date is conducted through the notarial system via the diathikes.gr platform under Law 5221/2025. The reform removes approximately 60,000–70,000 cases annually from the courts and reduces processing time from roughly 400 days to just three to seven days. From a private wealth perspective, the accelerated publication significantly narrows the post-death uncertainty window, enables heirs to proceed with transfers more quickly, and reduces the procedural bottlenecks that frequently trigger disputes.

However, given its limited flexibility in structuring more complex and multi-generational succession arrangements, which are often necessary in estates comprising diverse asset classes or in families seeking long-term preservation of wealth, alternative mechanisms have gained increasing traction in recent years.

Trusts and foundations

In this context, trusts (either inter vivos or hereditary) have emerged as a compelling tool.

Greece has not adhered to the Hague Convention of 1 July 1985 on the Law Applicable to Trusts and on their Recognition. As a result, trusts are not recognised in Greece from a regulatory standpoint. Nevertheless, foreign trusts and foreign foundations are recognised from a Greek tax law perspective, and administrative guidance has significantly increased predictability for Greece-connected private wealth planning. Since 2017, trusts have been fully regulated from a tax perspective in Greece, offering a more sophisticated framework for intergenerational wealth planning and asset protection.

The primary reference point is AADE Circular POL 1114/2017, which provides interpretative guidelines for the tax treatment of both foreign trusts and foreign foundations. The Circular describes the underlying relationships (settlor/founder, trustee/board, beneficiaries) during establishment, operation and termination, and provides a functional definition of each vehicle. In particular, it describes the trustee as holding the transferred assets as a distinct pool, separate from the trustee’s own property, and distributing them in accordance with the trust terms and for the benefit of the beneficiaries. Similarly, it defines a foreign foundation as a comparable mechanism – typically a legal entity under its home law, governed by statutes and internal rules, run by a council or board, with beneficiaries and benefits defined in its regulations.

From a private wealth perspective, these vehicles are increasingly considered when families seek outcomes that a will alone may not easily deliver, particularly where long-term governance and protection are required. Typical objectives include the following.

• The protection of minors or vulnerable beneficiaries through controlled administration and staged distributions rather than an immediate and potentially fragmented transfer of assets at a single point in time.
• The continuity of management across generations, where the trustee or foundation board can administer assets under a pre-set governance framework, limiting the risk of post-death paralysis or disputes among co-heirs.
• Risk management and asset separation objectives, to the extent compatible with the applicable legal framework and creditor protection rules. A defining characteristic described in the administrative guidance is that trust assets are managed by the trustee as a distinct pool, which is central to private clients’ asset protection thinking.
• Intergenerational preservation of wealth, given that the trustee holds legal title to the assets; as the beneficiaries do not directly own the assets, the wealth is less exposed to personal risks such as creditors, divorce or poor financial decisions.

It should be noted that asset protection through trusts or foundations is not absolute. Greek law gives creditors the right to challenge transfers of assets that were made to their detriment, meaning that if assets are moved into a trust or foundation primarily to place them out of creditors’ reach, a court may set aside that transfer (Civil Code Articles 939–946). For this reason, these structures should be driven by genuine succession and governance objectives, such as providing for minor children or ensuring continuity of family wealth management, and should be properly documented.

Greek law also recognises the concept of a foundation as a legal person, where assets are allocated by a founding act to serve a specific purpose. In practice, domestic foundations in Greece are generally structured as non-profit or public benefit entities under state supervision, with the legal framework for common benefit foundations addressed in Law 4182/2013. This means that, as a domestic Greek tool, foundations tend to be most relevant for legacy and philanthropy planning rather than as a private holding vehicle for family wealth. Foreign foundations may nonetheless appear in Greek-connected private wealth structures and are addressed together with foreign trusts in the AADE administrative guidance (POL 1114/2017).

The tax treatment of inter vivos trusts/foundations largely depends on the wording of the constitutional documents governing such distributions. In principle, the Circular recognised that the true intention of the settlor is to proceed to a gift, during their lifetime, to the designated beneficiaries. To this end, the settlor/founder transfers assets gratuitously from their estate under the management of the trustee/board or council and for the benefit of the beneficiaries, who have a simple expectation of receiving distributions from them. In principle, distributions from a testamentary trust fall within the scope of Greek inheritance tax rules; accordingly, the beneficiaries are treated as heirs for Greek tax purposes.

Finally, and in accordance with the Circular, the settlement of assets into an inter vivos/hereditary trust or foundation does not, in itself, constitute a taxable event for the beneficiaries. However, distributions from said vehicles to the beneficiaries, in principle, give rise to gift taxation in Greece, depending on the facts and the relationship between the parties.

Please note that the Circular clarifies that a trust is regarded as a succession planning vehicle and, as such, must reflect the genuine intention of the settlor to transfer their estate to the designated beneficiaries. At the same time, the Greek tax anti-avoidance framework applies to prevent artificial arrangements established solely for the purpose of securing tax advantages for the settlor.

It should also be noted that trust distributions from settlors or to beneficiaries who have opted into the 5A tax regime may qualify for exemption from Greek gift/inheritance tax to the extent that the trust assets consist of foreign assets.

Real estate owned by trusts

Greek real estate owned directly or indirectly through legal entities can trigger the annual 15% special real estate tax (SRET) under Law 3091/2002, unless a statutory exemption applies. In 2023, the Independent Authority for Public Revenue issued a long-awaited decision confirming the eligibility of Greek real estate property settled into a foreign trust for exemption from the 15% SRET, subject to specific documentation requirements. The decision addresses cases where shares in a Greek real estate-owning company are held (in most cases indirectly) by a foreign foundation or a trust, and sets out the type of documentation that must be retained and provided, including documents evidencing the ultimate beneficial owners and certain jurisdictional transparency requirements.

Therefore, trusts are now expressly recognised among the qualifying legal entities, alongside foundations, provided that both the trust and the trustee are established in a jurisdiction that is not classified as non-co-operative for tax purposes and both their full details and the details of the settlor and the beneficiaries are disclosed.

This marks a breakthrough novelty in succession alternatives in Greece, and is one of the most important regarding the majority of Greek residents’ assets being included in a trust arrangement.

Joint accounts/joint portfolio accounts and joint investor accounts

Until 2022, an exemption from Greek inheritance tax (IHT) was granted only to cash deposits and mutual funds held in joint bank accounts, while according to the standard practice of the Greek tax administration, the exemption applied only to accounts held with Greek bank institutions. Joint accounts have long been used in Greece as a practical, client-friendly way to ensure that liquidity and continuity are available to surviving family members without a lengthy administration process.

As of 2022, the IHT exemption for deposits maintained in joint bank accounts has been extended to joint bank accounts including cash deposits and all kinds of securities (portfolio accounts, joint investors account) that are held either in Greece or abroad (excluding jurisdictions that are deemed to be non-co-operative for tax purposes), provided that:

• either the foreign law governing the account provides that, upon the death of any account holder, the funds in the joint account are transferred automatically to the surviving account holders, meaning that no further (including legal) action is required for the acquisition of such funds; or
• the bank account documentation provides for a “succession clause” stating the above.

The above ΙΗΤ exemption extends to shares of non-listed companies held in a joint investment account (KEM) or its foreign equivalent, subject to certain conditions. The application of these provisions to KEMs holding non-listed securities is particularly significant in the context of inheritance, allowing family-owned companies to be transferred to the next generation without incurring any tax liability.

Joint structures can be very effective for speed and certainty, but they should be aligned with the overall succession plan to avoid an unintended concentration of assets in the surviving co-holder in a way that conflicts with the intended distribution among heirs.

Family offices and family business succession

Family offices regime

A Greek family office is typically established as a special purpose company whose sole purpose is to manage the wealth and affairs of a specific family. Key characteristics of the regime include the following.

• Local substance requirements: establishment in Greece with a genuine operational presence and a minimum number of employees (commonly at least five).
• Minimum operating expenditure: recent amendments reduced the annual required expenditure in Greece from EUR1 million to EUR500,000, making the structure accessible to a wider range of families.
• Permitted activities: management of investments and assets, financial planning and reporting, administrative and concierge services for family members, payment of expenses and co-ordination of service providers and advisory or administrative services in relation to trusts or foundations involving family members
• Single-family focus: services are provided exclusively to members of the family group.
• Incentivised formalisation: the framework encourages families to replace informal asset management arrangements with a structured, professional governance vehicle.

Beyond any tax considerations, the practical governance benefits are significant, including:

• centralised management of family assets and expenditures;
• continuity of decision-making across generations;
• preservation of institutional knowledge despite changes in leadership;
• professional reporting and accountability; and
• reduced risk of misunderstandings or disputes among family members.

Operating through a dedicated entity allows the family to implement consistent policies and maintain professional management even when key individuals retire or pass away.

Family business succession – governance tools to prevent disputes

For families owning operating businesses, succession risk arises primarily from fragmented ownership and unclear control after inheritance, especially where multiple heirs acquire shares. Without prior planning, co-ownership may lead to deadlock in decision-making, conflicts over dividends versus reinvestment, disputes over management roles, uncertainty regarding strategic direction, or pressure for premature sale or exit.

To mitigate these risks, succession planning increasingly focuses on governance arrangements implemented during the founder’s lifetime. Common legal and organisational tools include the following.

• Family charter (family constitution): sets out shared values, vision and long-term objectives, defines the roles of family members in ownership and management, establishes participation criteria and behavioural expectations, and provides guidelines for dividend policy or reinvestment.
• Shareholders’ agreements tailored for succession, covering:
1. voting arrangements and allocation of control;
2. board composition and appointment rights;
3. pre-emption rights on share transfers;
4. restrictions on transfers to third parties;
5. special majority requirements for key decisions;
6. deadlock resolution mechanisms (eg, arbitration, buy-sell triggers); and
7. liquidity or buyout pathways for heirs wishing to exit.
• Staged transition and successor preparation, covering:
1. gradual transfer of managerial responsibilities;
2. mentoring and training of next-generation leaders; and
3. avoidance of abrupt, unplanned transfer of control.
• Buy-sell and liquidity mechanisms, such as:
1. formula-based pricing clauses;
2. insurance-funded buyouts;
3. options for the company or remaining shareholders to purchase shares; and
4. protection of the company’s financial stability while compensating departing heirs.

These instruments translate the founder’s intentions into practical, enforceable rules governing the company after death. Clarifying rights, responsibilities and exit options in advance significantly reduces the likelihood of intra-family disputes and operational paralysis during a generational transition.

Inheritance law reform

Greece is in the middle of a transformative cycle for succession planning, combining procedural modernisation already in force with a comprehensive draft reform of inheritance law that the Justice Ministry has publicly presented and stated is planned to become law in the first quarter of 2026, subject to public consultation and final legislative text.

Forced heirship redesigned: from a proprietary right to a monetary claim

A central announced change is the transformation of forced heirship from a proprietary entitlement into an obligational right, taking the form of a monetary claim. This direction aims to reduce forced fragmentation of specific assets (such as real estate or business participations) and therefore reduce involuntary co-ownership structures that frequently lead to deadlock and disputes.

Inheritance contracts introduced for the first time

The draft provides for inheritance contracts and agreements renouncing future inheritance rights. These are described by the Ministry as new, flexible tools that allow earlier, rational organisation of post-death wealth allocation and reduce disputes and litigation risk. For the first time, Greek law would permit structured, binding lifetime agreements on the allocation of inheritance – a tool long available in other European jurisdictions and highly relevant for family business continuity planning.

A new approach to estate debts and heir liability

The Ministry has described a core reform: separating the estate’s liabilities from the heir’s personal property so debts are satisfied exclusively from the inherited estate. This would reduce “frozen estates” and the cascading renunciation dynamic that can pull in more distant relatives and create repeated deadline uncertainty.

Modern family realities: enhanced spouse/partner position and updated intestate rules

The announced reform agenda also addresses the modernisation of intestate succession, including strengthening the position of the spouse and the partner under a civil partnership agreement, and clarifying interpretive issues (including scenarios involving dissolution). It also notes, for the first time, the possibility (under strict conditions) for a partner in a free union to inherit in the fifth class.