What the tax system covers

Ordinary Greek-resident individuals are generally taxed on worldwide income. Articles 5A, 5B and 5C offer different conditional treatments for foreign income, foreign pensions and qualifying work; they are not interchangeable.

References [1][2][8]

When you become tax resident

Greek individual residence can arise from a permanent or principal home, habitual abode or centre of vital interests, including personal and economic ties. Presence exceeding 183 days during any twelve-month period is a further test, generally applying from the first day of presence. The official guidance describes a limited exception for exclusively tourism, medical or similar private stays not exceeding 365 days; this is not a general remote-worker exemption. Ordinary Greek residents are generally subject to worldwide income taxation, while nonresidents are taxed on relevant Greek-source income. A person retaining another home should examine the applicable treaty with the actual family and economic facts. Obtaining an AFM tax number or a golden-visa card does not alone establish the full residence conclusion. Record arrival, accommodation, family relocation and work activity so the first resident year can be supported.

References [1][2]

Rates and the tax base

9%–44% general progressive scale. The 2026 ordinary employment/pension scale uses 9%, 20%, 26%, 34%, 39% and 44% bands. Dependent-child and age rules can reduce lower bands; credits and social contributions are separate. Capital income has its own category rates.

References [2]

Private investment gains and business trading

Greece taxes specified securities gains, including unlisted shares and listed holdings meeting the statutory ownership test. Other securities and fund exemptions need separate review. Real-estate capital-gains taxation is suspended through 31 December 2026 under the cited guidance; this does not exempt property dealing as a business.

References [2]

Asset cost basis on arrival

Greece's ordinary taxable-securities rules look to acquisition value, with specific share and inherited-asset rules. Residence alone does not establish a new market value. The Canada–Greece treaty text includes a conditional election after a taxed departure deemed disposal, subject also to its protocol and treaty anti-abuse rules.

  • The ordinary-cost conclusion follows Article 42's cost mechanics; it is not an express universal rule for every asset entering Greece.
  • First determine whether the gain is taxable. Listed-share and qualifying fund exemptions do not create a new cost basis.
  • The Canada–Greece Article 13(6) election requires cessation of one contracting-state residence, immediate residence in the other, and a deemed alienation taxed by the departure state. It is not automatic or based on citizenship.
  • Protocol paragraph 2(iii) provides for replacement of the Article 13(6) election by a former-resident taxing-right rule if the relevant Canadian departure-tax rules are significantly amended or replaced. Confirm the operative treaty wording for the transaction; this guide does not establish that the replacement condition has been triggered.
  • The Canada–Greece treaty is also subject to the MLI principal-purpose test. A benefit can be denied where obtaining it was one of the principal purposes of an arrangement or transaction, unless granting it accords with the object and purpose of the relevant treaty provisions. Meeting the election's stated conditions does not dispense with that assessment.
  • Article 5A/5B alternative taxation and Article 5C employment/business relief are separate from acquisition-cost rules. Eligibility and the treatment after leaving a regime require review.
  • Greek submission procedure, deadline and treatment of deferred departure tax remain to be confirmed. Apply the MLI's effect dates and treaty-eligibility rules to the relevant tax period and actual circumstances.
  • The treatment of inherited or gifted foreign securities where no Greek inheritance or gift valuation was filed has not been established here. Confirm the applicable acquisition value before using a foreign probate or gift valuation.
Asset or situationStarting value and treatment
Purchased taxable securitiesArticle 42(3) compares sale receipts with acquisition price paid, including directly connected costs. A valuation obtained on moving is not the acquisition payment described by that rule.
Unlisted company sharesArticle 42(4) uses the lower of acquisition-date equity value and the acquisition contract price for cost; disposal value has a separate higher-value rule. Founder shares and capital changes need their history.
Listed shares and fund unitsAADE lists exemptions for listed holdings below 0.5%, relevant pre-2009 traded securities and qualifying Greek/EU/EEA/EFTA fund profits. Confirm legal form and eligibility; a foreign ETF label alone is insufficient.
Inherited or gifted securitiesUse the value on which inheritance, gift or parental-gift tax was calculated, or an exemption granted, under Article 42(4). This acquisition event is not an immigration revaluation.
Private immovable-property gainsArticle 41 is suspended through 31 December 2026 under Law 5162/2024 Article 90. This time-limited suspension does not establish arrival basis or settle business-property income and foreign-source issues.
Business ownership and business assetsA share sale and a business's disposal of its underlying assets are different events. Do not apply a shareholder's Article 42 calculation to stock, equipment or other operating assets without a business-income review.
Qualifying move from CanadaArticle 13(6) describes an elected deemed sale and repurchase at fair market value immediately before arrival after a taxed departure deemed disposal and the required residence transition. Check Protocol 2(iii), the principal-purpose test and the Greek election procedure before relying on that value.

A Canadian departure needs a separate treaty check

The treaty text includes an election, not automatic relief. Assemble residence dates, the departure assessment and asset valuations, then establish the operative protocol wording and treaty eligibility before deciding which value belongs in the Greek calculation.

QuestionEvidence needed
Did residence transfer immediately?The facts establishing departure and Greek residence.
Was this property subject to a taxed deemed disposal?The relevant assessment and property schedule.
What fair market value applies?Support for the value at the treaty's specified time.
Does the election remain operative?Check Protocol 2(iii)'s conditional replacement provision against the relevant Canadian departure-tax legislation.
Does the arrangement meet the anti-abuse test?Assess its purposes and the object and purpose of the treaty provisions; keep evidence of the actual circumstances.
How is the election made?Confirmed Greek procedure and treaty eligibility; these remain implementation questions.

Articles 5A, 5B and 5C target different income profiles

Article 5A allows qualifying new residents to pay €100,000 annually on covered foreign income, with a €20,000 family extension per qualifying relative, for up to fifteen years. It generally requires nonresidence in seven of the previous eight years and a €500,000 qualifying investment completed within three years, subject to the statutory investment-permit exception. A property residence permit does not automatically prove that exception.

Article 5B is directed at eligible foreign pension recipients and generally applies a 7% charge to foreign income for up to fifteen years, with its own prior-residence and cooperation-country conditions. Article 5C provides a 50% exemption for qualifying Greek employment or business income over seven years, subject to its separate work, prior-residence and intended-stay tests. These regimes cannot be treated as interchangeable discounts or simply applied to every new resident’s entire income.

References [8]

Special-regime compliance continues after admission

The Article 5A application and investment-evidence timetable, annual fixed payment and completion deadline should be recorded separately. Failure to pay or complete the qualifying investment can have materially different consequences, including loss of current treatment or unwinding of benefits. The foreign fixed-tax amount is not a credit that automatically offsets every foreign withholding tax or covers Greek-source income.

For any regime, classify each income stream by source, taxpayer and legal nature before comparing ordinary taxation. A pensioner with large non-pension foreign income needs a different model from an employee or founder selling a business. Review Greek property and other asset obligations separately. The official incentive guide is the starting point for programme criteria; obtain current filing instructions and the individual approval before treating the intended result as implemented.

References [8][2]

Apply for the tax-register change with substantive evidence

AADE has a specific procedure for transferring personal tax residence abroad. For the ordinary following-year procedure, its published framework calls for an application by the first ten days of March after departure and supporting documentation by the first ten days of September, with the detailed rules governing later submissions and older years. Confirm the current process and any applicable deadline before relying on a date.

The file needs evidence of genuine residence abroad, not simply a flight or foreign tax number. A foreign tax-residence certificate, official foreign assessment or accepted alternative, together with housing, employment and other relocation evidence, may be needed. AADE states a two-month period to decide the completeness and adequacy of the evidence after submission. That procedural period does not guarantee acceptance or replace the underlying residence test.

References [14][15]

Address the continuing home and family connections

Greek residence can follow the home, habitual abode or centre of vital interests even apart from a day threshold. A departing individual should explain retained property, spouse and children, business duties and the intended duration of the move. A spouse remaining in Greece does not justify ignoring the individual facts, but it makes the supporting analysis particularly important.

Review the destination’s residence test and the relevant treaty where both countries claim residence. Keep the travel ledger consistent with the Greek and foreign filings. Updating AADE’s registry is important administration; it should reflect a defensible legal position rather than be treated as an elective switch that creates nonresidence despite unchanged facts. Retain the approval and the complete evidence file after the move.

References [1][14][15]

Close arrival-regime obligations before assuming they stop

Article 5A has annual-payment and qualifying-investment obligations that need a departure or revocation review. Failure to complete the investment is different from electing to stop participation after compliance, and the consequences can reach earlier benefits. Article 5B and Article 5C likewise have their own duration and cessation conditions. Obtain a written account of the final year and any required notification.

Moving an owner does not automatically move a company. If Greek management, staff, assets or contracts also transfer, review corporate residence, permanent establishment, valuation and the applicable corporate exit provisions. The corporate framework should not be described as a universal personal portfolio exit tax. CFC attribution to an individual or entity also depends on the relevant residence and ownership facts for the year.

References [8][2][16]

Foreign companies and income attribution

Article 66 can attribute specified undistributed foreign income to both individual and corporate taxpayers. The tests include more than 50% control alone or with associated enterprises, actual foreign tax below half the Greek-law counterfactual, and more than 30% of pre-tax net income in the specified categories. Those categories include interest, royalties, dividends/share disposals, financial leasing, financial activities and low-value related-party invoicing. A substantial economic activity exception exists, but does not extend to a CFC resident or established in a third country outside the EEA.

References [17][18]

Departure, migration and continuing obligations

The taxpayer definition in Article 66A covers resident legal persons/entities and Greek permanent establishments. It does not itself establish a general deemed sale of an individual’s private portfolio on departure. A departing owner must separately test any company or PE migration, retained Greek-source income and the administrative transfer of personal residence.

References [17][18]
Sources & research notes18 references