Greece Article 5A tax regime: investment, annual charge and application

Eligibility & suitability

Which taxpayer and which income

Article 5A concerns eligible individuals moving their tax residence to Greece. AADE’s November 2025 guidance describes a €100,000 annual charge on foreign income and a fifteen-year framework. Greek-source income remains a separate question. It is not a rate available to every foreign company owned by the individual.

The prior-residence condition is non-residence in seven of the preceding eight years. A qualifying investment of at least €500,000 is generally required and must be completed within the prescribed three-year window, with a specific exception described by AADE. Do not assume that every golden-visa property automatically meets that exception.

Assess the economics before making the investment

Model the household’s actual foreign income over several scenarios. Include low-income years, planned disposals, foreign withholding and tax in other source countries. Compare the annual charge, investment costs and continuing administration with ordinary taxation and alternative jurisdictions.

Separate the applicant’s income from a spouse’s, a trust’s or a company’s income. Establish source and classification before applying a favourable label. A structure still needs to function commercially, and work or management conducted in Greece requires its own analysis.

Application and supporting records

The AADE guide sets out a March 31 application deadline and an investment-evidence process. Assemble prior-residence documentation, the intended tax-arrival date, qualifying investment material and any family-extension evidence. Confirm the current procedural rules for the relevant year before filing.

Prepare a written schedule showing the applicable deadline, who makes each payment and which evidence must be retained. Document any uncertainty about the investment or income source before committing funds. A tax-election approval should not be mistaken for an immigration permission.

Protect the position over time

Failure to complete the investment or make required payments can have significant consequences under the regime. Maintain an annual review of compliance and the investment, including changes to ownership and family participation. Prepare for the end of the election or an earlier move before making large asset transactions.

We can integrate this review with residence, banking and business implementation. The useful deliverable is not merely confirmation that a regime exists, but a defensible explanation of why the household qualifies and what must happen to keep the plan working.

Prior residence and the investment requirement

Article 5A generally requires non-residence in Greece for seven of the preceding eight years and a qualifying Greek investment of at least €500,000. The investment must be completed within three years of the inclusion application. AADE describes a specific exemption where an applicant holds and maintains the referenced investment-activity residence permission; do not assume every golden-visa property automatically satisfies that exception.

The investment and tax-residence application must be coordinated. AADE’s guidance calls for evidence of the minimum funds transferred to a Greek financial institution and permits applications at commencement or within the specified period after completion. Decide what qualifies before buying an asset. The rule allowing completion later is not permission to ignore the deadline or substitute any expenditure for a qualifying investment.

Annual payment and loss of the regime

The foreign-income charge is €100,000 annually, with €20,000 for each included relative, for a maximum 15-year period. Relatives can be added later under the updated provisions for the remaining years. Covered foreign income and ordinary Greek-source income must be distinguished. The fixed charge may be unattractive when foreign income is low or subject to heavy tax elsewhere.

AADE states that failure to pay the full annual amount ends the treatment for the relevant year, while failure to complete the qualifying investment can unwind inclusion from the beginning. This difference matters: one failure can expose earlier years to ordinary worldwide taxation. Maintain separate calendars for annual payment and investment completion, with documentary evidence rather than reminders alone.

Application date and family planning

The general inclusion deadline is 31 March of the relevant year. The current guidance also addresses applicants who moved in the preceding year and the timing of later family inclusion. Confirm which case applies before choosing a relocation date. A tax application does not supply immigration permission for a third-country national.

Prepare a model covering foreign income, Greek work or property income, the investment’s commercial costs and each relative’s receipts. Review foreign movable-property gift and inheritance treatment under the exact Article 5A conditions rather than interpreting it as a universal exemption for every estate asset. Any planned company migration or trust distribution needs separate classification.