Three alternative taxation regimes were introduced in 2020 by the Greek Government, aiming exclusively at attracting foreign tax resident individuals into Greece.
A challenging project, it consists of three distinct tax incentive regimes carefully customized to the needs and aspirations of three potential audiences: high net worth individuals (HNWI)-investors, pensioners and active professionals. Launched at critical times for Europe, considering the post-Brexit immigration concerns for both individuals and body corporates, these special tax arrangements aspire to compete successfully with similar ones available in other European countries. This triple bundle of tax incentive regimes comes as a natural complement to the traditional strongholds of this country, such as natural beauty, mild climate, top-graded lifestyle, a delicious-yet healthy-cuisine, as well as its recent achievements, such as the steadily notable management of the COVID pandemic, and put Greece forth as a prime option for relocation.
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“The HNWI (“Non-dom”) tax regime.
Being practically a flat tax regime, it is tailored for individuals wishing to invest and reside in Greece on favourable terms, enjoying the quality of everyday life to the fullest. Qualifying individuals should (a) have held their tax residence outside Greece for at least 7 out of the previous 8 years; (b) directly or indirectly invest at least 500.000€ in Greek assets; and (c) complete the investment within 3 years from the application date. Multiple benefits are granted to them: (a) payment of a lump sum/flat tax of only 100.000€ annually on the non-Greek source income; (b) no obligation to declare in Greece any income earned outside the country; (c) exemptions from inheritance/donation tax on non-Greek property and income; and (d) possibility of the regime’s full extension to family members, by paying an extra lump sum of 20.000€ for each of them. Full application of Double Tax Treaties between Greece and other countries comes as an addition, while “non-dom” persons in Greece are entitled to a Greek Tax Residence Certificate on the same conditions with regular Greek tax residents. Implemented in practice for a year now, the HNWI regime is considered particularly attractive, applied through a straightforward procedure, minimum supporting documentation and no annual minimum stay. Compared to other countries’ similar regimes, it offers one of the lowest flat taxes and one of the longest durations (15 years).
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The foreign pensioners special tax regime.
Following the HNWI regime, it was enacted in 2020, addressed to pensioners who receive their pensions outside Greece. Beside the country’s widely known characteristics – safety, culture, sunshine, high living standards - this regime is the best choice available to pensioners wishing to reside at an ideal location with minimum taxation: a flat tax of 7% on their non-Greek source income, including their pension, furthermore exempt from the Special Solidarity Contribution. Qualifying individuals should (a) be receiving a foreign pension; (b) have their tax residence outside Greece for at least 5 out of the last 6 years; and (c) be former residents in a country honouring an administrative cooperation agreement with Greece, regardless of their nationality or citizenship. Full application of the Double Taxation Treaties between Greece and other countries and the ability to get a Greek Tax Residence Certificate is also provided. The distinct advantage of this Greek regime, compared to other similar European regimes, is the total absence of an investment requirement, a minimum annual stay period, as well as any geographical restriction: the pensioners may reside anywhere in Greece, without even purchasing a piece of real estate, while the duration of their special arrangement may reach a significantly long period of 15 years. The application procedure is also straightforward, requiring minimum supporting documentation.
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The foreign employees and entrepreneur’s alternative taxation status.
As the third and most recent tax incentive arrangement introduced by the Greek Government, it aims at attracting foreign tax resident individuals, regardless of their nationality or citizenship, to relocate and actively work in and from Greece. Addressed to employees, executives, freelancers and entrepreneurs, it offers a 50% income tax relief on Greek-sourced salary or business income and on the corresponding special solidarity contribution over a period of 7 years. A tax allowance from “deemed income” rules on the use of residence and vehicle also applies. Said initiative became effective as of 1st January 2021 and is a decent effort to transform Greece’s “brain drain” into “brain regain”, to create new job positions, to establish Greece as a hub of highly qualified employees and to attract, in this context, executives and companies leaving the UK after Brexit. Qualifying individuals should (a) have held their tax residence outside Greece at least 7 out of the last 8 years; (b) relocate from an E.U. or E.E.A. member state or a country that honours an administrative cooperation agreement with Greece; (c) provide services in Greece in the context of an employment relationship with a Greek legal entity or with a permanent establishment of a foreign company in Greece, or exercise individual business activity in the country; and (d) declare that he/she will remain in Greece for at least two (2) years. Notably, qualifying individuals may enter this regime under the condition of filling only new job positions.
Connect with a Grant Thornton expert to further discuss any of the alternative taxation regimes:
• Konstantinos Kounadis, Tax & IBC Director (konstantinos.kounadis@gr.gt.com)
• Chryssanthi Miliou, Senior Manager, Private Client Tax Services (chryssanthi.miliou@gr.gt.com)
