GREECE Trends and Developments Contributed by: Petros Machas, Ioannis Charalampopoulos and Vasileios Tsintzos, Machas & Partners
permanently reside in Greece and a series of invest - ment migration programmes that cater specifically to non-EU citizens. These two schemes can also be combined to create a winning proposition for eligi - ble investors seeking to optimise their wealth man - agement strategies or address their global mobility concerns, which have become more relevant under the current global geopolitical situation. Greece’s non- dom tax regime provided for a favourable tax envi - ronment for HNW individuals everywhere across the globe. The basic requirement is to invest a minimum of EUR500,000 in Greece. Entering the non-dom regime, one becomes a tax resident in Greece and is liable for an annual lump-sum tax of EUR100,000, regardless of one’s income abroad. In 2023, the administration further simplified the process, establishing a more investor-friendly experience for non-dom applicants. The regime allows a maximum of up to three separate investments in different categories, allowing changes to investments within three years of the initial appli - cation, permitting changes after the completion of the investment and accepting different sources of funding for the amount of the investment exceeding the minimum of EUR500,000. On 23 February 2024, an amendment was introduced by the Ministries of Finance, Development and Investments. This aimed to simplify the Greek non-dom tax regime, providing a straightforward process and resolving issues hin - dering the benefits of this tax regime, by addressing delays in registering notarial deeds with Land Regis - tries and Cadastral Offices. Certification of investment completion is granted with a one-year extension in pending registration cases. The Greek non-dom tax regime relies on a flat annual tax of EUR100,000 for all foreign sourced income, with an additional EUR20,000 for family members. A mini - mum investment of EUR500,000 in real estate, bonds/ securities or Greek legal entities is required within three years. Only income within Greece is declared, with no inheritance or gift tax imposed on assets held outside, maintaining this advantage for up to 15 years. The Greek Minister of Finance has announced major forthcoming reforms to align the regime with leading jurisdictions:
• family members will be able to join at any point in time during the 15-year period, with a flat tax of EUR20,000 per person; • full exemption from Greek taxation on foreign gifts and inheritances, facilitating wealth transfer plan - ning; and • streamlined procedures and faster approvals, enhancing legal certainty. Prospective applicants can benefit from both the Greek non-dom tax regime and the Golden Visa scheme with the same one investment in Greece. Family Offices: Incentives and Announced Enhancements The Ministry of Finance has announced substantial enhancements to the legal framework for family offic - es (Article 71H of Law 4172/2013, Ministerial Decision A.1043/2022) to strengthen Greece’s position as a hub for global family wealth management. The proposed changes include: • reduction of minimum annual operating expenses in Greece from EUR1 million to EUR250,000; • expansion of permitted activities, including advi - sory services to trustees for trusts where family members are settlors or beneficiaries; and • greater flexibility in structure and cross-border operations to support complex wealth manage - ment needs. Currently, family offices must: • employ at least five staff in Greece within 12 months of establishment; • have minimum annual operating expenses in Greece of EUR1 million; • apply a 7% profit margin on operating costs to determine gross revenue; • provide asset, investment, personal and philan - thropic management within a regulated framework; and • offer comprehensive services covering adminis - tration, finance, compliance, strategic planning, succession and more, ensuring robust support for UHNW families.
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