The law 4646/2019 voted in December 2019 offers tax incentives to wealthy individuals who choose to profit from an alternate tax regime for their income earned outside Greece. It is a “non-domicile” programme aiming to attract high net-worth individuals in order to relocate their tax domicile to Greece.
The new legislation introduces a flat tax rate of €100,000 annually on income earned worldwide for a period of 15 years for eligible candidates. They will be exempt from the requirement to report and be taxed locally on their foreign source income, while being required to pay the flat tax rate of €100,000 on their foreign source income regardless of its origin.
The beneficiaries may include first degree relatives by paying the additional fixed amount of €20,000 annually per additional family member. The main applicant and family members are also exempt from any taxation abroad pertaining to donations, inheritances and/or parental provision of foreign assets. It is important to note that any income generated in Greece will be taxed according to the tax regime applicable to Greek taxpayers. The applicants will qualify as tax residents of Greece and will be eligible for protection under the 57 international tax treaties for the avoidance of double taxation that Greece shares with foreign countries.
The two main requirements an applicant needs to fulfil:
- The applicant was not a tax resident of Greece in the last 7 years from a total of 8 years prior to transferring his/her tax residency to Greece.
- The applicant needs to invest a minimum amount of 500,000.00€ in Greek real estate or movable assets and/or shares in legal entities based in Greece. The investment may be fulfilled either by the main applicant or by a first degree relative or via a legal entity where he/she is the majority shareholder and should be completed within 3 years from the tax residency transfer application.
- As 1 st degree relatives are considered the spouse, parents, or children of the beneficiary.
- The tax exemption is in effect from the 1 st fiscal year for which the application is eligible to file and remains in effect for 15 fiscal years.
- Taxes paid abroad or tax discounts occurring from the beneficiary’s Greek income are not offset against the fixed amount.
- The applicant may request to be excluded at any time.
Payment terms of annual tax
- 1st year: Within 30 days from the application’s approval in a single instalment.
- 2nd year onwards: Until the last working day of July in a single instalment.
The application may be submitted to the tax authorities until March 31 st of each year.
The Tax authority replies within 60 days from the application date.
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