On 25th of July, Law No. 5222/2025 (Government Gazette: Issue 134 A’/28.07.2025) entitled "National Customs Code and Other Provisions – Pension Provisions" was enacted by the Hellenic Parliament.
This new law entirely replaces the existing National Customs Code of Greece, with the aim of aligning it with the Union Customs Code and international conventions ratified by the country. It responds to the profound changes and modern requirements that have emerged across various sectors of international trade and technological development. In parallel, the law introduces a comprehensive set of tax provisions, which affect almost the entirety of the tax legislation. Among other things, it includes significant amendments to the Income Tax Code, the Tax Procedure Code, the VAT Code, and the Code governing Inheritance, Gift, Parental Benefit, and Gambling Winnings Taxation. Additionally, it brings changes to the Greek Accounting Standards, the business activity tax, and other regulatory provisions.
A. Purpose of the New Law
The new law pursues a dual objective:
- On the one hand, it aims to simplify and accelerate the operation of the country’s customs system through the digitalization of customs procedures and transactions.
- On the other hand, it seeks to safeguard public revenue by strengthening tax compliance and combating tax evasion. At the same time, it contributes to the promotion of tax justice, facilitates both taxpayers and tax authorities, and supports the achievement of strategic objectives.
B. Key Amendments Introduced by the New Law
1. Income Tax Code
- Alternative taxation regime for foreign-source income of individuals transferring their tax residence to Greece (non-dom):
- The requirement for individuals who are tax residents abroad and transfer their tax residence to Greece to take up new employment in order to be eligible as employees is abolished.
- The obligation of the Greek Tax Administration to notify the tax authorities of the taxpayer’s previous country of residence is now subject to the principle of reciprocity, thereby eliminating any unilateral obligation on the part of the Greek authorities.
- An individual investor who transfers their tax residence to Greece is exempt from inheritance or gift tax in Greece for movable property located abroad, received either by themselves or by third parties as a result of inheritance or donation, respectively.
- Employer-provided medical expense coverage: As of 1 January 2025, benefits granted by an employer to cover the cost of medical treatment or hospitalization for an employee or their close relatives are excluded from taxable employment income.
- Tax treatment of income earned by seafarers on private leisure vessels: Income earned by seafarers serving on private recreational vessels is subject to separate (flat) taxation, in alignment with the treatment of officers and crew members of commercial vessels.
- Electronic payment of rent: In cases where rental is not paid through the banking system:
- Rental not paid electronically by a business is not considered as a tax deductible business expense.
- Property-related expenses are not tax deductible from the landlord’s taxable income.
- The tenant becomes ineligible for any benefit, allowance, or subsidy related to the lease.
- Special Purpose Family Wealth Management Companies (Family Offices):
- Reduction of minimum expenditure threshold: The minimum required annual operating expenses incurred in Greece are reduced from €1,000,000 to €500,000.
- Expansion of permitted activities: Family Offices may now provide advisory services to trustees in relation to trusts in which individuals or their family members participate as settlors or beneficiaries.
- Tax residency safeguard: The provision of services by a Greek Family Office to foreign companies affiliated with the individuals or their families does not constitute the exercise of effective management of those companies in Greece.
2. Tax Procedure Code
- Issuance of Tax Clearance Certificate without Withholding on the Sale Price: Individuals jointly liable under Article 49 of the Tax Procedure Code (TPC), who held a participation of less than 5% during the last two years of their term, may, under specific conditions, obtain a tax clearance certificate without withholding and proceed with the transfer of real estate (by sale, parental gift, or donation), even if the company has outstanding tax liabilities to the State.
- Establishment of the Real Estate Ownership and Management Registry: A Real Estate Ownership and Management Registry is established as a digital registry maintained by the Independent Authority for Public Revenue (AADE), centralizing all information regarding the ownership and management of real estate assets.
- Fines for Transporting Goods Without Supporting Documents: Stricter penalties are introduced for the transportation of goods without the required transport documentation:
- The fine increases from €500 to €5,000 for entities subject to the single-entry (simplified) accounting system.
- The fine increases from €1,000 to €10,000 for entities subject to the double-entry (accrual-based) accounting system.
3. VAT Code
- Determining the place of supply and taxation of services relating to access to cultural, artistic, sporting, scientific, educational, entertainment or related events, as well as ancillary services related to access.
- Revision of the special scheme for small businesses as regards their exemption from the obligation to pay Value Added Tax (VAT) for the supply of goods and services.
- Reduction from 13% to 6% of the VAT rate on the importation of works of art, collections or antiquities, as well as the supply of works of artistic value by the creator and his successors.
Greece’s 2025 Tax reform: Major changes to Family Offices and Non-Dom regime
4. Inheritance, Gift, Parental Benefit and Gambling Winnings Tax Code
- Decrease of the minimum ten-year period to five-year period of residence abroad for Greeks who have settled abroad and acquired movable property there, in order for such foreign-located movable property to be exempt from inheritance tax in Greece.
- Exemption from donation taxation, of they hospitalization payments by an employer for an employee or his relative.
5. Other provisions
- Establishment of a specific framework for the approval of corporate transformations of persons supervised by the Bank of Greece, the Hellenic Capital Market Commission and the Gambling Control and Supervision Committee.
- Reactivation of the procedure before the Committee for the Extrajudicial Resolution of Tax Disputes, enabling taxpayers to apply for extrajudicial dispute resolution by 24 July 2026 for pending cases that have not been requested before the Council of State and the regular administrative courts by 23 July 2026.
Grant Thornton, fully understanding the needs of its clients, stands by your side during significant legislative changes, providing support in both the interpretation and implementation of new regulations. Our specialized professionals are available to present the recent legislative developments through a detailed seminar or presentation.
Related Services
We work at an impressive pace. Yours. Discover how:
