Greece’s Tax Incentive Programs for New Residents in 2026

A summary of Articles 5A, 5B and 5C of the Greek Income Tax Code (Law 4172/2013)

January 6th, 2026.

Greece has implemented three distinct tax regimes aimed at attracting foreign individuals to establish tax residence in the country. Introduced at the close of 2019 as Articles 5A, 5B and 5C of the Greek Income Tax Code (Law 4172/2013), and amended most recently by Law 5222/2025 (July 2025), these frameworks offer different benefits depending on the applicant’s circumstances and income sources. This guide examines each regime’s key provisions as currently in force.

ALTERNATIVE TAXATION FOR HIGH-NET-WORTH-INDIVIDUALS (Article 5A of Law 4172/2013)

Greece’s first regime targets affluent individuals seeking to relocate by offering a simplified tax structure for their overseas earnings.

KEY COMPONENTS

This regime operates through a fixed annual payment rather than traditional income tax calculations. Participants pay €100,000 per year, which covers all taxation obligations on earnings generated outside Greece, regardless of total income levels or diversity of sources. This arrangement eliminates the need to report foreign earnings to Greek authorities.

The annual payment follows a specific schedule: subsequent years require payment by the final business day of July, while the initial year’s payment must be completed within one month of programme acceptance.

The regime lasts for a maximum of fifteen years from initial enrolment.

The programme includes provisions for family inclusion. Participants can extend coverage to close relatives — spouse, parents, and children (children receive automatic coverage) – for an additional €20,000 per person annually. Following the amendments introduced by Law 5222/2025, family members can now be added at any stage during the regime’s duration, not only at the time of the initial application. Where relatives are added later, the beneficial provisions apply from the first tax year in which the extension is approved, for the remaining period until the completion of fifteen years from the date of the initial applicant’s enrolment.

A significant advantage involves estate planning: assets held internationally remain outside Greek inheritance and gift tax jurisdiction. Law 5222/2025 extended this exemption to cover not only foreign movable assets received by participants (by inheritance or gift) but also foreign movable assets transferred by participants to others. This extension applies retroactively to inheritances from 1 January 2020 onward.

Domestically-sourced earnings remain subject to standard Greek taxation, and no credits apply for foreign taxes paid on income covered under this regime. Participants receive formal Greek tax residency status, recognised under international tax treaties.

Non-payment of the lump sum tax results in reverting to standard worldwide income taxation rules.

ELIGIBILITY REQUIREMENTS

Qualifying demands meeting two primary criteria:

First, applicants must demonstrate they held tax residence outside Greece for at least seven of the eight years preceding their relocation.

Second, within three years of enrolment, applicants must deploy at least €500,000 in qualified investments. These can be made personally, through family members as legally defined, or via controlled entities. Acceptable investments include:
Greek property acquisition or development
Equity stakes in unlisted Greek companies (through initial capitalisation, capital increases, or secondary purchases)
– Greek government debt instruments with minimum three-year maturity at purchase, held through Greek financial institutions
– Contributions to Greek-domiciled alternative investment funds under regulatory supervision
– Securities traded on Greek exchanges, including equities, bonds, ETFs, and government instruments
– Shares or corporate bonds of Greek Real Estate Investment Companies (REICs)

This investment requirement is waived for holders of specific investment-related residence permits, including the Golden Visa. Given the significant overlap between Golden Visa applicants and Article 5A candidates in practice, this waiver is worth noting at the outset.

Following completion of the investment, participants must maintain it for the duration of their enrolment and submit annual documentation to the tax office (by 31 May each year) evidencing continued maintenance.
While no minimum physical presence requirement exists in legislation, applicants should demonstrate genuine intention to centre their lives in Greece through maintaining a primary residence. Meeting standard residency tests – either the centre-of-vital-interests criterion or the 183-day presence threshold – helps prevent challenges from prior jurisdictions.

ENROLLMENT PROCESS

Applications must reach the relevant tax authority by 31 March of the intended tax year, accompanied by banking documentation confirming the transfer of investment funds to a Greek account. This is a hard deadline – there is no extension mechanism and no late filing option. Applications filed after 31 March are automatically deferred to the following tax year, meaning a missed deadline delays enrolment by a full twelve months.

Family extension requests may accompany the initial application or, following the Law 5222/2025 amendment, be submitted at a later stage. Authorities issue determinations within sixty days, during which applicants must provide all supporting documentation.

Applicants must disclose their previous tax residence jurisdiction. Greek authorities will notify that jurisdiction of the residence transfer, subject to reciprocal information-sharing agreements.

ALTERNATIVE TAXATION FOR FOREIGN PENSIONERS (Article 5B of Law 4172/2013)

This regime provides favourable treatment for individuals receiving retirement income who choose to establish Greek residency.

CORE FEATURES

Unlike the lump-sum approach above, this regime applies a uniform 7% rate to all foreign-sourced income (not limited to pensions), provided such income is not exempted by applicable tax treaties. All overseas earnings must be declared in annual Greek tax returns alongside any domestic income.

Tax payment occurs in a single instalment, typically by the last business day of July following the tax year. Missing the year-end payment deadline triggers immediate programme termination.

The regime runs for a maximum of fifteen years from enrolment. It does not provide inheritance or gift tax benefits for international assets, but does recognise credits for foreign income taxes paid. Greek-sourced income faces standard taxation.

Participants obtain formal Greek tax residency status and can request residency certificates. Unlike the 5A regime, no family extension option exists.

Programme exit – whether voluntary or through revocation – results in standard worldwide taxation for those remaining in Greece.

QUALIFICATION STANDARDS

Applicants must meet three conditions:

First, they must receive retirement payments from foreign social security systems, government entities, occupational pension schemes, or lump-sum/annuity insurance payouts from private insurers under group retirement plans.

Second, they must not have held Greek tax residence for at least five of the six years before applying.
Third, their prior tax residence must have been in a country maintaining a valid agreement on administrative cooperation in the field of taxation with Greece. Greece currently has such agreements with over fifty-five countries, but applicants from jurisdictions without such agreements – particularly certain Middle Eastern and African countries – will not qualify regardless of meeting the other conditions.

Though no explicit presence requirement exists, substantial time in Greece is advisable, along with attention to treaty-based residency determination factors.

APPLICATION PROCEDURE

Applications are due by 31 March of the relevant tax year. As with Article 5A, this is a hard deadline – late submissions are deferred to the following year. Authorities decide within sixty days. Applicants must identify their prior tax residence, enabling Greek authorities to notify that jurisdiction under reciprocal cooperation principles.

ALTERNATIVE TAXATION FOR EMPLOYMENT AND FREELANCE ACTIVITY (Article 5C of Law 4172/2013)

The third regime targets individuals earning income from Greek employment or self-employment activities. Often referred to as the “brain gain” regime, it was designed to encourage both the return of Greek professionals who left during the debt crisis and the relocation of skilled foreign workers.

PRINCIPAL BENEFITS

This regime provides a 50% exemption on annual Greek-sourced income from salary or business operations. The remaining half faces taxation under standard progressive rules, combined with any other Greek or foreign income.

All income must appear on annual tax returns. The regime does not exempt international assets from Greek inheritance or gift taxes.

Participants are exempt from the deemed income calculations (τεκμήρια) typically applied to Greek residents based on residence and vehicle ownership expenses. This can be a meaningful practical benefit, as deemed income rules can otherwise inflate the taxable base for individuals whose declared income appears low relative to their lifestyle expenditure.

Coverage extends for up to seven years from enrolment. Participants achieve formal Greek tax residency status and may simultaneously opt into either the 5A or 5B regime if they meet the respective criteria.

Note on solidarity contribution: Earlier versions of this regime referenced exemption from the special solidarity contribution on 50% of income. The solidarity contribution was fully abolished for all income categories from 1 January 2023. The statutory language still references it, but in practice the exemption is now academic – there is no contribution to be exempted from.

PREREQUISITES

Law 5222/2025 (July 2025) made an important change to the eligibility conditions for this regime. Previously, applicants taking up employment in Greece were required to demonstrate that they were filling a “new employment position” – a condition that created practical difficulties and delayed applications. This requirement has been eliminated. The abolition applies not only to new applications but also retroactively to applications that were pending before the tax administration as of 28 July 2025.

The current conditions are:

– Applicants must not have been Greek tax residents for five of the six preceding years.
– Prior residence must have been in an EU/EEA member state or a country with which Greece has a valid agreement on administrative cooperation in the field of taxation.
– Applicants must provide services under a Greek employment relationship (including board positions or executive roles with Greek permanent establishments), or must commence taxable self-employment activities based in Greece.
– Applicants must declare their intent to remain in Greece for at least two years. This is not merely a formality: departure from Greece before the two-year period results in revocation of the regime, with standard worldwide taxation applying from the tax year of departure.

PROGRAMME TERMINATION

The regime ends – and standard taxation resumes – if the employment relationship or business activity ceases for more than twelve consecutive months without the participant commencing a new qualifying activity, upon voluntary withdrawal, or upon reaching the seven-year maximum.

ENROLMENT

For employment or self-employment activity beginning by 2 July, applications are due by year-end. For activity starting after 2 July, applications are due by the end of the subsequent year and processed for that year.

Determinations arrive within sixty days. Supporting documents must be filed within this period, though remedies exist for rejections based on documentation delays.

As with other regimes, applicants must identify their prior tax residence for reciprocal notification purposes.


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.

Practical Considerations Across All Three Regimes

The March 31 deadline is absolute (for 5A and 5B). There is no discretionary extension. Applicants who miss the deadline – even by one day – wait a full year. Planning should work backwards from this date.

Residency substance matters. While none of the regimes imposes a statutory minimum-presence requirement, applicants should be aware that their previous jurisdiction may challenge the transfer of residence if they do not demonstrate genuine relocation. Maintaining a primary residence, establishing local banking and social ties, and meeting either the 183-day or centre-of-vital-interests test provides the strongest defence.

Regime combination is possible. A 5C participant can simultaneously elect into 5A or 5B, provided they meet the relevant conditions. This can be advantageous for high-net-worth professionals with both Greek employment income and significant foreign passive income.

Greek-source income is always taxed normally. All three regimes provide benefits only for foreign-sourced income (5A and 5B) or a reduction on Greek employment/business income (5C). Any other Greek-source income – rental income from Greek property, Greek dividends, Greek interest – is taxed under standard rules in all cases.


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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