GREECE Trends and Developments Contributed by: Petros Machas, Ioannis Charalampopoulos, Vasileios Tsintzos and Sofia-Maria Sventzouri, Machas & Partners
• Inclusion of family members: the regime now allows family members to be included at any time during the principal investor’s 15-year period of tax residency under the non-dom regime, subject to an annual fee of EUR20,000 for each additional family member. • Enhanced tax Exemptions: additional tax incen - tives have been introduced to address disincen - tives identified under the existing framework, including: (a) a full exemption from gift and inheritance tax on foreign assets that are acquired by the investor; and (b) an exemption from Greek gift and inheritance tax in respect of such foreign assets when transferred to third parties by way of gift or succession. Furthermore, pursuant to Article 94 Law 5313/2026 (Government Gazette A’ 102/25.06.2026), additional amendments were introduced to Article 5A of the Greek Income Tax Code, further enhancing the flex - ibility of the Greek non-dom tax regime. In particular: • the deadline for payment of the annual flat tax has been extended from July to 31 December of each tax year; and • the previous statutory deadline requiring applica - tions to be submitted by 31 March has been abol - ished ‒ the new application procedure, the appli - cable submission deadlines and the timeframe for the examination of applications by the Greek tax authorities are expected to be determined through a forthcoming Ministerial Decision. Prospective applicants can benefit from both the Greek non-dom tax regime and the Golden Visa scheme through the same investment in Greece. Family Offices: Incentives and Announced Enhancements The Ministry of Finance has introduced substantial enhancements to the legal framework for family offic - es (Article 71H 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 EUR500,000; • 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. Eligibility of Transparent Trust Structures With Equity Participation in Real Estate Companies Decision No A.1089/2023 of the Independent Author - ity for Public Revenue has resolved the controversies concerning the special real estate tax provisions which were recently reinstated in Articles 18 et seq of the Property Tax Code, introduced under Law 5219/2025, which unified the real estate taxation framework. This decision clarifies the exemption eligibility of transpar - ent trust structures with equity participation in real estate companies, allowing them to be exempted from the special real estate tax (of 15% on the property’s tax value) by determining the requisite documentation for the applicability of the exemption. More specifi - cally, trusts are now included in the qualifying legal entities, along with foundations, provided that the trust has been construed in accordance with, and is governed by, the laws of a jurisdiction that is not con - sidered a non-cooperative tax jurisdiction (where the establishment of the trustee shall be located as well). This decision constitutes a remarkable development, allowing estate and succession planning for sophis -
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