buying real estate in greece – individual versus company ownership
Personal Holdings vs. Corporate Vehicles for Greek Real Estate – Comparing the tax position under current law (February 2026)
February 3rd, 2026.
One of the first questions foreign investors ask us is whether to acquire Greek property in their own name or through a company. The answer depends on what you plan to do with the property, how much income it will generate, and how you intend to exit. Neither structure is inherently superior – each creates a distinct tax profile, and the right choice depends on your specific circumstances.
Here is how the two structures compare under current Greek tax law, following the reforms introduced by Law 5246/2025 (effective 1 January 2026).
RENTAL INCOME
Individuals pay tax on rental income under a progressive scale that was revised from January 2026:
15% on income up to €12,000
25% on income from €12,001 to €24,000
35% on income from €24,001 to €36,000
45% on income above €36,000
The taxable base is gross rental income less a flat 5% deduction for expenses. This 5% is applied automatically in lieu of actual expenses – you cannot deduct mortgage interest, insurance premiums, or maintenance costs from rental income as an individual. (A separate 40% tax credit exists for qualifying renovation and energy-efficiency expenditure, spread over five years up to a maximum of €16,000, but this is not a deduction from rental income – it reduces your income tax bill directly.)
Companies (IKE, SA, or EPE) are taxed on net profit at the flat corporate income tax rate of 22%. All legitimate business expenses are deductible: maintenance, insurance, management fees, accounting, legal costs, and – critically — interest on loans used to acquire or improve the property. Companies can also claim fiscal depreciation on the building value at 4% annually, creating a non-cash expense that shields rental income from taxation. If corporate profits are distributed to shareholders, a further 5% dividend withholding tax applies. This means the combined effective rate on fully distributed rental profits is approximately 25.9% (22% corporate tax, then 5% on the remaining 78%).
What this means in practice: For rental income up to roughly €24,000, individual ownership now produces a lower effective tax rate than a corporate structure distributing all profits – especially after the 2026 reform reduced the second bracket from 35% to 25%. The corporate structure becomes more attractive at higher income levels, or where significant deductible expenses (particularly loan interest and depreciation) reduce the corporate taxable base well below gross income.
EXPENSE DEDUCTABILITY AND DEPRECIATION
This is where the structural difference is sharpest.
An individual landlord receiving €50,000 in annual rent can deduct €2,500 (5%) and pays tax on €47,500. Under the 2026 scale, the tax is approximately €15,150.
A company receiving the same €50,000 but carrying €10,000 in deductible expenses (maintenance, insurance, management, accounting) and claiming €8,000 in building depreciation (4% on a €200,000 building value) has a taxable base of €32,000. Corporate tax at 22% is €7,040. If fully distributed, add 5% dividend withholding on the €24,960 net profit: €1,248. Total tax burden: €8,288 – roughly 55% less than the individual.
The gap narrows dramatically for a low-cost, unlevered property. If the company has minimal expenses and the building’s depreciable value is small, the corporate structure’s advantage shrinks and may be outweighed by the compliance costs of maintaining a Greek company (accounting, annual filings, GEMI registration, tax representative costs).
ANNUAL PROPERTY TAXES (ENFIA)
Both individuals and companies pay ENFIA (Unified Real Estate Ownership Tax) on property held as of 1 January each year. The main tax is calculated identically regardless of ownership structure, based on location, size, floor level, age, and use. The difference lies in the supplementary tax. For individuals, this is progressive (rates from 0.1% to 1.15%) and applies when total property holdings exceed certain thresholds. For legal entities, it is a flat 0.55% of total property value – or 0.1% if the property is used for the entity’s own business activity (e.g., a hotel, office, or commercial operation).
For a high-value portfolio, the flat 0.55% corporate rate may be lower than the progressive individual rate. For a single property of moderate value, the difference is negligible.
THE SRET COMPLIANCE REQUIREMENT
Companies holding Greek real estate must ensure they are exempt from the Special Real Estate Tax (SRET) – a 15% annual levy on the property’s objective (cadastral) value. This is an anti-avoidance measure, not a general tax: it targets opaque ownership structures. But the compliance requirements to secure the exemption are not trivial, and have been tightened by AADE Decision A.1014/2026 (February 2026).
To qualify for exemption, the company must:
– Disclose all ultimate beneficial owners (UBOs) as natural persons
– Register UBO information in the national Beneficial Ownership Register maintained by AADE
– Ensure all disclosed UBOs hold a Greek TIN (AFM) as of 1 January of the tax year
– Not have any entity in the ownership chain established in a non-cooperative jurisdiction
– Maintain documentary evidence and produce it on request
For entities relying on the economic activity exemption (where business income exceeds real estate income), the 2026 decision clarifies that dividends, interest, and royalties are excluded from the “business income” calculation, and mixed lease-plus-services contracts must be unbundled.
Failure to comply means the full 15% SRET applies – which will almost certainly exceed any tax advantage the corporate structure was designed to achieve. Any investor using a corporate vehicle must budget for the ongoing compliance cost and treat it as a non-negotiable requirement.
CAPITAL GAINS ON SALE
Individuals: Capital gains tax on the sale of real estate is currently suspended through 31 December 2026. This suspension has been extended repeatedly since it was first introduced – it has been in effect continuously since 2013. While there is no guarantee of further extension, the pattern is relevant context. If and when it takes effect, the rate will be 15% on the gain. The suspension does not apply if the frequency and volume of sales constitutes a “business activity.”
Companies: There is no suspension. Any gain realised on the sale of property is treated as ordinary business income and taxed at 22%. There is no participation exemption or reduced rate for real estate disposals.
This is the single largest advantage of individual ownership for investors with a clear exit strategy. On a property purchased for €300,000 and sold for €500,000, the individual pays nothing (under the current suspension); the company pays €44,000 in corporate tax on the €200,000 gain – plus dividend withholding if the profit is distributed.
OWNER OCCUPANCY
If you intend to use the property yourself rather than rent it, individual ownership is simpler. Living in your own property creates no income tax event, though Greece’s imputed income rules (τεκμήρια) may increase your deemed minimum expenditure based on the property’s size and value, which in turn affects your overall tax position.
If a shareholder uses a company-owned property free of charge, it creates tax friction in two directions. The company may be assessed deemed rental income (typically 3% of the objective value), taxable at 22%. Separately, the benefit may be treated as a benefit in kind for the shareholder, increasing their personal income tax liability. Either way, the tax authorities will not accept that a company owns a property that nobody pays for.
OTHER CONSIDERATIONS
Digital transaction fee. Since 1 December 2024, a 3.6% digital transaction fee applies to certain agreements including commercial property leases where VAT does not apply. This replaces the previous stamp duty and is an additional cost to factor into the corporate leasing structure.
Long-term rental incentive. Under Law 5246/2025, individuals who lease previously vacant or short-term-let residential properties on long-term contracts (minimum 3 years, property up to 120 m², lease concluded by 31 December 2026) can qualify for a 36-month income tax exemption on the rental income. This incentive is available only to natural persons – corporate landlords cannot claim it. For qualifying properties, this significantly tilts the analysis toward individual ownership during the exemption period.
EU Parent-Subsidiary Directive. If the Greek property-holding company is owned by an EU-resident parent company holding at least 10% for a minimum of 24 months, dividends paid upstream may be exempt from the 5% Greek withholding tax. This changes the effective combined rate for corporate structures used by EU-based investors.
Compliance costs. A Greek company (IKE or SA) requires annual accounting, tax filings, GEMI registration, and – for foreign-owned structures – typically a local tax representative and ongoing beneficial ownership reporting. Budget €3,000–€8,000 per year depending on complexity. This fixed cost reduces the corporate structure’s advantage for lower-value or lower-income properties.
SUMMARY COMPARISON
Rental income tax
Individual: Progressive: 15%–45%
Company: Flat 22% on net profit + 5% on dividends (~25.9% combined)
Expense deductions
Individual: Flat 5% only
Company: All business expenses deductible
Building depreciation
Individual: Not available
Company: 4% per year on building value
Capital gains on sale
Individual: Suspended (0%) through 2026
Company: Taxed as profit at 22%
ENFIA supplementary rate
Individual: Progressive (0.1%–1.15%)
Company: Flat 0.55% (or 0.1% for business-use property)
Cash access
Individual: Immediate
Company: Requires dividend distribution
SRET compliance
Individual: Not applicable
Company: Mandatory – UBO disclosure, Greek TINs, annual documentation
Long-term rental exemption
Individual: Available (36 months, conditions apply)
Company: Not available
Annual compliance cost
Individual: Minimal
Company: €3,000–€8,000+
WHICH STRUCTURE IS RIGHT?
Individual ownership typically suits investors who are acquiring one or two properties for capital appreciation with eventual resale, have moderate rental income (under ~€24,000), plan to benefit from the CGT suspension on exit, can qualify for the long-term rental tax exemption, or intend to use the property personally.
Corporate ownership typically suits investors with high-yielding properties (where the 45% top bracket bites), properties requiring significant renovation (to utilise expense deductions and depreciation), leveraged acquisitions (where loan interest deductibility matters), portfolios where succession planning, asset protection, or multi-generational holding is a priority, or EU-based structures that can eliminate dividend withholding.
The decision should be made before acquisition – restructuring later triggers transfer taxes (3.09%) and potentially other costs. We advise modelling both structures with your specific numbers before committing.
For a personalised analysis based on your investment profile, contact us.
Disclaimer
The content on this website is provided for general informational purposes only and does not constitute legal advice. It should not be applied to any particular legal matter or factual situation without consulting a qualified attorney. Kanellos & Associates makes no commitment to keep this information current and assumes no liability for any losses or damages arising from your reliance on the content provided herein.
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