GREECE Trends and Developments Contributed by: Theodore Rakintzis, Panagiotis Pothos, Angeliki Miliakou and Petros Roumpis, Kyriakides Georgopoulos Law Firm
On top of that, individuals under this regime enjoy full Greek inheritance and gift tax exemption on foreign assets they receive or transfer to others. The regime lasts 15 years, although participants can opt out at any time. Close family members can also join, with an extra annual tax of EUR20,000 per person. Please note that individuals from third countries (ie, non-EU nationals) may also qualify for a Golden Visa through the same investment, provided that the spe- cific conditions set out in the relevant residence permit legislation are met. The “5B tax regime” or “foreign pensioner’s regime” This regime is suitable for retirees who receive a pen- sion from abroad (ie, outside of Greece) and seek a low, flat tax rate on their foreign-source income, long- term certainty and a high quality of life within the EU. To qualify, applicants must not have been Greek tax residents for five of the six years prior to the transfer, and must receive a foreign pension from social secu- rity institutions or group pension plans. In addition, their last tax residence must be in a country that co- operates with Greece on tax matters. Under the regime, participants pay 7% tax on foreign- source income, while income generated in Greece is subject to standard Greek tax rates. The regime lasts 15 years, but it cannot be extended to family mem- bers, who must each apply separately. The “5C tax regime” or “50% tax break regime” This regime is designed for employees and self- employed professionals moving to Greece, and offers a 50% tax exemption on Greek employment or professional income. It is particularly attractive for executives, specialists and entrepreneurs looking to relocate. To qualify, applicants must not have been Greek tax residents for five of the six years prior to the move. Their last tax resident must be in an EU or EEA country or in a state that co-operates with Greece on tax matters. Finally, they must provide services in Greece for a Greek employer or as a self-employed professional and commit to residing in Greece for at least two years. The regime lasts seven years, provid- ing a clear window of tax relief for newcomers.
As the 5C regime is linked to employment/working in Greece, third-country nationals must hold a residence permit that grants the right to work in the country (a Golden Visa does not confer working rights). Why succession and estate planning are important in Greece Succession planning in Greece is moving towards a broader family wealth continuity strategy, driven by the following three main practical realities. • Asset fragmentation remains a recurring issue for families with more than one heir and more than one material asset (eg, a family home alongside a sec- ond residential or commercial property, shares in a family business or cash/cash equivalent portfolio). Under the inheritance law rules, in the absence of a will, heirs end up in joint ownership structures that create difficulties in asset exploitation and enjoy- ment and – most importantly – are the source of significant interfamily frictions and disputes going forward. This becomes even more serious in the case of family business shares, where an inherited business requires uninterrupted decision-making and a clear control model. A reform agenda is currently under the final stages of consideration, with inheritance law legislation recently launched by the Hellenic Ministry of Justice identifying these matters of concern and framing key changes as tools to prevent the “splitting” of inherited assets or businesses. • The speed and certainty of the first estate adminis- tration steps are becoming a central private wealth concern. Greece has already implemented a major procedural modernisation: the publication of wills (holographic, sealed and public) is routed through a digital workflow and handled by notaries via an electronic portal (diathikes.gr), with the stated goal of taking tens of thousands of cases out of the courts and compressing timelines from several months to just a few business days. • There is a clear market shift toward governance solutions that reduce disputes and preserve value across generations. This includes the increasing relevance of trust and foundation-based structures where appropriate, particularly for governance, the protection of minors and vulnerable beneficiaries, and asset protection objectives within the limits of
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