Greece: non-⁠dom €100k and benefits for pensioners and workers

Concept

Greece offers three preferential tax regimes for those who move their tax residence to the country — under Articles 5A, 5B, and 5C of the Tax Code. The principal one is the non-dom regime (resident but not domiciled), with a flat tax of €100,000 a year on all foreign-source income.

These are tax regimes; they do not grant the right to reside. Immigration is decided separately: EU citizens enjoy freedom of movement, everyone else arranges a Golden Visa or another basis, and the 5A investment is conveniently combined with a residence-by-investment permit.

Non-⁠dom €100k (Art. 5A)

• a flat tax of €100,000 a year on all foreign-source income, whatever its size;
• a term of up to 15 tax years;
• an added €20,000 a year for each family member (with no separate investment);
• entry condition: you were not a Greek tax resident for 7 of the last 8 years;
• an investment of at least €500,000 in real estate, a business, or securities within three years (or a current Golden Visa);
• Greek-source income is taxed at the normal rates and declared.

Pensioners: 7% (Art. 5B)

For foreign pensioners who move their residence to Greece, all foreign income — pension, dividends, interest, rent, capital gains — is taxed at 7% for up to 15 years. Conditions: you were not a Greek resident for 5 of the last 6 years, and you arrive from a country with which Greece has an agreement on administrative cooperation in tax matters. The tax is paid in a single instalment by the last working day of July and does not override the application of double-tax treaties.

Workers and self-employed: 50% (Art. 5C)

For those who move their job or business to Greece, half of Greek employment or business income is exempt from tax for seven years; there is no extension. Conditions: you were not a Greek resident for 5 of the last 6 years, you relocate from an EU/EEA country or a state with an administrative-cooperation agreement, you take a new position with a Greek employer or start activity here, and you commit to staying at least two years. Deemed income on housing and a car is not charged in this case.

Immigration

Greece is a member of the EU and Schengen. EU/EEA citizens move without a visa; non-EU applicants go through the Golden Visa (thresholds €250k–€800k, covered in a separate article) or other permits. For 5A, the investment is often combined with a Golden Visa.

Context

The Greek non-dom is a flat sum, as in Italy, but cheaper: €100,000 against the €300,000 to which Italy raised its regime (Art. 24-bis TUIR, Presidential Decree No. 917 of 22 December 1986; from 1 January 2027, Article 246 of the new Consolidated Income Tax Act, Legislative Decree No. 117 of 19 June 2026, Art. 377) for those transferring residence from 1 January 2026 — Article 1, paragraph 25 of Law No. 199 of 30 December 2025 (the 2026 Budget Law). Earlier entrants keep their own figures, and there are three cohorts: €200,000 for those who transferred residence after Decree-Law No. 113 of 9 August 2024 came into force (10 August 2024), and €100,000 for those who transferred before that date. Greece, however, requires a €500,000 investment, while Italy does not. Comparable in logic are the Spanish Beckham Law, the Swiss forfait, and the UK regime after the 2025 non-dom reform; Turkey taxes foreign income at zero, but without a flat payment. The choice comes down to the size of the income and the willingness to tie up capital. Articles 5A, 5B and 5C sit as three separate rows on one grid with fifteen other regimes — what is exempt, term, entry price, presence, prior non-residence, family and election deadline — in special tax regimes, with a worked example on €2,000,000 of passive income; the Golden Visa that most often carries the 5A investment is compared with the other European investor routes in investor routes in Europe.

Risks

• the €500,000 investment for 5A is a real tying-up of capital;
• Greek-source income is taxed normally (progressively, up to 44%);
• the flat sum is paid regardless of income; the regime pays off only with a large foreign income;
• leaving a jurisdiction requires checking any applicable CFC and exit-tax rules and, if relevant, a treaty residence tie-breaker; these do not arise merely because of departure or nationality. For 5B, Greece requires an administrative cooperation agreement in tax matters with the state from which tax residence is transferred. Separately, any treaty relief must be checked against the provisions currently in force, including Russian suspensions where relevant. (Sources: AADE: Article 5B; FNS: CFC; HMRC: CFC).

How and when to file

The application for 5A and 5B is filed with the tax authority (AADE) by 31 March of the relevant tax year; a decision on 5A is normally issued within 60 days. For 5C, the deadline depends on the start date of employment: if it begins before 2 July, the application is filed by the end of that year, and if later, by the end of the following one.

The exit logic is strict: if in any year the flat tax (€100,000 or 7%) is not paid in full, the benefit is cancelled, and from that year all worldwide income is taxed on general terms. Under 5A, foreign income need not be declared, and tax paid abroad is not credited in Greece; under 5B and 5C, both Greek and foreign income are declared.

That silence has a limit set by EU law. Directive (EU) 2023/2226 (DAC8) extended the automatic exchange of advance cross-border rulings to rulings on the tax affairs of individuals from 1 January 2026. A ruling issued, amended or renewed after that date is exchanged where the transaction amount stated in it exceeds €1,500,000, or where the ruling determines whether a person is tax resident in the issuing state; the same test also widened the definition of a cross-border ruling itself (Art. 3(14) of Directive 2011/16/EU). For 5A this bites harder than for neighbouring regimes: foreign income is not declared in Greece, so the AADE decision admitting an applicant to the regime is the only document that records the applicant's tax status at all.

Whether a 5A approval falls inside that perimeter turns on national classification: the exchange runs on what a Member State itself treats as an advance cross-border ruling, and Greece also operates a separate advance-ruling procedure. The timetable is open too — on 30 January 2026 the Commission sent Greece a letter of formal notice for failing to transpose DAC8, so the domestic schedule trails the European one. The provision is not retroactive: a 2021 approval that simply remains in force is not exchanged. Amendment or renewal after 1 January 2026 brings it wholly into exchange, and planning built on the Greek status staying private ends at that step.

Evolution and place among European regimes

Greece launched these regimes in 2019–2020, recovering from the debt crisis and competing for mobile capital with Italy, Portugal, and Cyprus. The aim was to attract wealthy residents, foreign pensioners, and returning professionals — each group got its own article: 5A, 5B, and 5C.

Since then the neighbours have tightened their rules: Portugal closed the classic NHR and replaced it with the narrow IFICI regime, the UK abolished non-dom status from 2025, and Italy raised its flat tax to €300,000. Against this backdrop, the Greek package with a €100,000 entry payment and a 15-year horizon looks like one of the most stable offers in the EU.