GREECE Trends and Developments Contributed by: Petros Machas, Ioannis Charalampopoulos and Vasileios Tsintzos, Machas & Partners
pursuant to Article 38 of Law 5162/2024 (Government Gazette Α’ 198), two alternative tax regimes are availa - ble for newly established venture capital mutual funds. This includes the existing tax transparent regime or a tax opaque regime where the mutual fund is subject to tax at a rate equal to 5% of the applicable inter - est rate for main refinancing operations of the Euro - pean Central Bank’s Eurosystem, with the difference between the value of the capital’s corporate participa - tions on December 31st of each tax year and the cost of acquiring the corporate participations, increased by the cumulative operating expenses of the fund; pay - ment of such tax exhausts the tax obligations of its unitholders. Since the beginning of 2025, there has been a nota - ble surge in enquiries from Greek start-up founders seeking to connect with potential international inves - tors via the Golden Visa scheme. Concurrently, pro - spective investors have expressed heightened interest in exploring equity opportunities in these start-ups, reflecting a maturing ecosystem and increasing con - fidence in Greece’s innovation potential. The new leg - islation requires: • a minimum investment of EUR250,000 into the share capital or bond issuance of start-ups listed in the Elevate Greece registry; • investor equity participation must not exceed one third of the company’s share capital or voting rights; and • the invested start-up must create at least two new jobs within the first year and maintain those jobs for a minimum of five years, ensuring sustained economic impact. Other Eligible Investments of the Greek Golden Visa Regime The Golden Visa programme, initially popular among real estate investors seeking lifestyle benefits, has expanded to other asset classes – these tend to become traditional asset classes as Greece evolves into a prominent venue for the global investment eco - system. Under the revised legal framework, non-EU nationals may obtain a residence permit through a wide variety of eligible investments.
• A fixed-term deposit of at least EUR500,000 in a Greek credit institution for at least one year, with a standing renewal order. This pathway is particu - larly attractive to individuals seeking a low-risk and straightforward route to residency, without the need for active asset management. • Purchase of Greek government bonds (EUR500,000 minimum) with a residual maturity of at least three years, held through a Greek custodi - an bank, offering a combination of sovereign credit security and reliable returns. • Purchase of units or shares in an alternative invest - ment fund (AIF) – EUR350,000 minimum – provided the fund invests exclusively in Greece and main - tains assets of at least EUR3 million. This option offers professionally managed exposure to the Greek market and is suited to investors who value diversification and passive participation. • Purchase of shares, corporate bonds or Greek government bonds – EUR800,000 minimum – sup - porting the domestic capital market. This route provides access to potentially higher yields while simultaneously supporting the domestic capital market. • Purchase of units in a mutual fund – EUR350,000 minimum – focused on Greek-listed securities, offering diversified access to Greek financial instru - ments through a regulated collective investment vehicle. • Capital contribution to a Greek regulated company – EUR500,000 minimum, supporting local enter - prise while offering direct equity involvement. • Capital contribution to a real estate investment company (REIC) – EUR500,000 minimum – invest - ing solely in Greece, providing a regulated and indirect exposure to the Greek real estate sector. • Capital contribution to a venture capital company (VCC) or mutual fund of business holdings (MFBH) – EUR500,000 minimum – investing exclusively in Greek companies, ideal for those seeking to support Greek innovation and entrepreneurship through private equity channels. Investment Migration and Related Tax Benefits Capitalising on the numerous opportunities that Greece is currently offering comes with very signifi - cant benefits for foreign investors: an attractive non- dom tax regime for all HNW individuals who do not
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