GREECE Trends and Developments Contributed by: Theodore Rakintzis, Panagiotis Pothos, Angeliki Miliakou and Petros Roumpis, Kyriakides Georgopoulos Law Firm
Greek law and family office arrangements as “oper- ating platforms” for co-ordinated family wealth management. Against this background, the trend in Greece is shift- ing away from reactive, post-death problem-solving towards proactive planning, with clear testamentary documentation, governance design (especially for business families) and structures that reduce frag- mentation and uncertainty at the moment of transition. Commonly used succession planning mechanisms Wills The will remains the traditional and most common- ly used succession planning instrument in Greece. Increasingly, wills are treated as operational instru- ments designed to prevent the typical failure modes that arise after death (fragmentation of assets, ambi- guity, and involuntary co-ownership disputes). Two features of Greek succession law make early planning particularly critical: • forced heirship (reserved portion), under which descendants, parents and the surviving spouse or registered partner who would inherit intestate are entitled to a share generally equal to half of their intestate entitlement; and • estate debt exposure, as heirs may be liable for estate obligations unless acceptance is carefully structured. Accordingly, will drafting should focus on avoiding unintended co-ownership of key assets, ensuring clarity as to who inherits what, when and under what conditions, and creating an implementable distribu- tion plan supported by accurate asset mapping and consistent ownership documentation. From 1 November 2025, the publication of wills for deaths occurring after that date is conducted through the notarial system via the diathikes.gr platform under Law 5221/2025. The reform removes approximately 60,000–70,000 cases annually from the courts and reduces processing time from roughly 400 days to just three to seven days. From a private wealth perspec- tive, the accelerated publication significantly narrows the post-death uncertainty window, enables heirs to
proceed with transfers more quickly, and reduces the procedural bottlenecks that frequently trigger dis- putes. However, given its limited flexibility in structuring more complex and multi-generational succession arrange- ments, which are often necessary in estates compris- ing diverse asset classes or in families seeking long- term preservation of wealth, alternative mechanisms have gained increasing traction in recent years. Trusts and foundations In this context, trusts (either inter vivos or hereditary) have emerged as a compelling tool. Greece has not adhered to the Hague Convention of 1 July 1985 on the Law Applicable to Trusts and on their Recognition. As a result, trusts are not recognised in Greece from a regulatory standpoint. Nevertheless, foreign trusts and foreign foundations are recognised from a Greek tax law perspective, and administrative guidance has significantly increased predictability for Greece-connected private wealth planning. Since 2017, trusts have been fully regulated from a tax per- spective in Greece, offering a more sophisticated framework for intergenerational wealth planning and asset protection. The primary reference point is AADE Circular POL 1114/2017, which provides interpretative guidelines for the tax treatment of both foreign trusts and foreign foundations. The Circular describes the underlying relationships (settlor/founder, trustee/board, benefi- ciaries) during establishment, operation and termina- tion, and provides a functional definition of each vehi- cle. In particular, it describes the trustee as holding the transferred assets as a distinct pool, separate from the trustee’s own property, and distributing them in accordance with the trust terms and for the benefit of the beneficiaries. Similarly, it defines a foreign foun- dation as a comparable mechanism – typically a legal entity under its home law, governed by statutes and internal rules, run by a council or board, with benefi- ciaries and benefits defined in its regulations. From a private wealth perspective, these vehicles are increasingly considered when families seek out- comes that a will alone may not easily deliver, par-
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