GREECE Law and Practice Contributed by: Nikolaos Koulocheris, Ioannis Charalampopoulos, Rozita Karasso and Dimitra Kotsovelou, Machas & Partners
lated market and in any case upon the lapse of three years from its incorporation, the REIC’s share capital must be invested at least 50% in real estate. Subsequently, the REIC is subject to the supervision of the Capital Market Com - mission both as a listed company bound by the relevant regulatory provisions and with regard to compliance with the specific applicable legisla - tive framework. Real estate mutual funds have not been so pop - ular in Greece, but REICs have gained signifi - cant popularity over the past years due to their special tax treatment and other tax incentives especially for foreign investors. In particular: • REICs are subject to a special corporate tax calculated at a rate equal to 10% of the interest rate provided by the European Central Bank for main refinancing operations increased by one percentage point imposed on the average of the fair market value of their investments including cash items. The special tax exhausts the obligations of the company for income tax in respect of their income from the investment real estate properties; • no dividend withholding tax is imposed on dividends distributed by REITs, but REICs are required to pay a minimum annual divi - dend equal to 50% of their annual net prof - its, excluding those related to capital gains from the sale of real estate, unless otherwise agreed with by the general meeting of share - holders with an increased majority of 80%; • REICs are exempt from the real estate transfer tax upon the purchase of real estate (3.09% of the value of the property); and • the acquisition of shares in a REIC constitutes an eligible investment for the purposes of the alternative taxation regime for foreign- sourced income of natural persons who transfer their tax residence to Greece under
Article 5A of Law 4172/2013, as well as to the residence permit regime for investment activity under Article 16 of Law 4251/2014, provided that the REIC’s investments are made exclusively in Greece. Following the introduction of Law 5193/2025, the eligible investments of REICs have been expanded to include, inter alia, the exploitation and management of real estate for the purpose of commercial profit or any other benefit, for any residential, industrial, commercial or other purpose, including but not limited to hotel and general tourist activity, the exploitation of energy production and storage structures from renewa - ble energy sources, and the exploitation of park - ing spaces, marinas, shopping centres, parks or data centres. 5.4 Minimum Capital Requirement The minimum share capital for the establishment of a société anonyme is EUR25,000. The estab - lishment of a private company requires the issu - ance of at least one share part with a minimum nominal value of EUR1. The corporate capital of the private company may be formed by capital contributions in cash or in kind, non-capital con - tributions of work, services or other assets not subject to valuation and/or guarantee contribu - tions consisting of an undertaking of liability for obligations of the company vis-à-vis third par - ties. The minimum required share capital for a société anonyme to be licensed as a REIC was raised to EUR40 million with the introduction of Law 5193/2025, which must be contributed in full and may consist of contributions in cash and money market instruments, real estate or tradea- ble instruments that serve the operational needs of the company, as well as shares of companies that invest in or exploit real estate. REICs must maintain at all times an equity position at least equal to EUR40 million.
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