Residence follows the home and vital interests as well as days
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.
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.
The business needs an independent Greek tax analysis
A personal arrival regime does not determine where a company is resident, where its services are performed or whether an overseas entity has a Greek permanent establishment. Examine actual strategic and daily management, signing authority, personnel and records. A founder working from Greece can affect those facts even without opening a registered branch. Salary, dividends and retained corporate profit are different tax layers.
AADE’s Article 66 CFC circular expressly concerns natural persons, legal persons and legal entities with qualifying controlled foreign companies. It is therefore inaccurate to describe Greece’s CFC framework as relevant only to corporate shareholders. The control, foreign-tax, income and exception conditions need their own calculation. A genuine overseas business should be supported by accounts and operational evidence; a foreign registered office alone does not settle attribution, residence or transfer-pricing questions.
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.
Sources & research notes4 references
Sources supporting this guide. Research draft awaiting editorial review.