Professional expatriates (50% exemption) – Foreign pensioners (7%) – High-net-worth investors (€100k lump sum)
Geneva, 5 August 2026 | Reviewed and updated: 18 October 2026
Greece operates three distinct alternative tax regimes for new residents, each aimed at a different profile: the working professional, the retiree, and the wealthy investor. They are not variations of one regime – they differ in what income they shelter, what they demand in exchange, and how they fail. The table compares them criterion by criterion; the observations that follow set out the practical issues.
The comparison follows articles 5C, 5B and 5A respectively. “Non-dom” is a convenient market label: these are tax-residence incentives, not immigration permissions. The 2026 procedural changes are incorporated below. [1-5]
| Criterion | Professional expatriates (50% exemption) | Foreign pensioners (7% flat rate) | High-net-worth investors (€100k lump sum) |
|---|---|---|---|
| Target profile | Employees and individual entrepreneurs, including freelancers, relocating to work in Greece. | Individuals receiving a qualifying foreign pension. | Wealthy individuals with substantial foreign income. |
| Core benefit | 50% of qualifying Greek employment and/or individual business income exempt from income tax. This is a reduction of taxable income, not a 50% tax rate. | 7% annual tax on foreign-source income of all categories, subject to applicable treaty exemptions or special treaty treatment. | €100,000 annual tax on foreign-source income, regardless of amount. €20,000 per relative whose inclusion is approved. |
| Scope of the benefit | Qualifying Greek earnings only; other income follows ordinary rules unless separately covered by an approved article 5A or 5B regime. | Foreign-source income only; Greek-source income follows ordinary rules unless separately qualifying under article 5C. | Foreign-source income only; Greek-source income follows ordinary rules unless separately qualifying under article 5C. |
| Prior non-residence | Non-Greek tax resident for 5 of the last 6 years before transferring tax residence. | Non-Greek tax resident for 5 of the last 6 years before transferring tax residence. | Non-Greek tax resident for 7 of the last 8 years before transferring tax residence. |
| Origin condition | Prior residence in an EU/EEA state or a state with a tax administrative-cooperation agreement with Greece. | Prior residence in a state with a tax administrative-cooperation agreement with Greece. | No equivalent origin-country condition, but the investment condition below applies. |
| Activity / investment condition | Employment exercised in Greece with a Greek entity or a Greek permanent establishment of a foreign enterprise, or Greek individual business activity. Qualifying Greek public-sector employment is also covered. Commitment to remain in Greece for at least 2 years. [3] | Receipt of a qualifying foreign pension under article 12 ITC, including a qualifying periodic or lump-sum pension. No Greek work or minimum investment is required. | At least €500,000 in eligible Greek real estate, businesses, securities or shares, completed within 3 years of application. A statutory exception exists for the qualifying investment-activity residence permit; it is not a general €400,000 alternative. [1] |
| Physical presence / residence | Genuine Greek tax residence and the 2-year commitment are required. The 183-day test is one residence test, not the only one. [6] | Genuine Greek tax residence is required. Permanent or principal residence, habitual abode and vital interests also matter; more than 183 days is not a universal annual minimum. [6] | Genuine Greek tax residence must be established and sustained. An immigration permit alone does not establish tax residence. [2,6] |
| Family extension | No automatic family extension; each person must qualify individually. | No automatic family extension; each person must qualify individually. | Spouse/civil partner and direct ascendants or descendants may apply at €20,000 each, without a separate investment. Special rules apply to minor children and their own foreign income; see below. [2] |
| Duration | Maximum 7 tax years. | Maximum 15 tax years. | Maximum 15 tax years. A relative admitted later receives only the remaining years. |
| Application deadline | For work/business starting by 2 July: apply by 31 December for that year. For a later start: apply by 31 December of the following year for that following year. See timing note below. [3] | Apply by 31 October of the relevant arrival/following year under the 2026 procedure; missing documents by 30 November. The 2 July arrival cut-off affects the first eligible year. [4] | Apply by 30 September of the relevant arrival/following year; missing documents by 31 October. The 2 July arrival cut-off affects the first eligible year. [2] |
| Foreign tax credit | Ordinary domestic and treaty credit rules apply to foreign income taxed ordinarily. | Foreign tax credit is available under article 9, within the Greek tax attributable to that income, where the treaty permits both states to tax or no treaty applies. Excess foreign tax is not refunded. [4] | No credit for foreign tax against the €100,000 levy. Treaty relief at source must be examined separately. |
| Estate planning | No specific inheritance or gift-tax benefit under article 5C. | No specific inheritance or gift-tax benefit under article 5B. | Greek inheritance/gift-tax exemption for foreign-situated movable property received by the beneficiary or transferred by that beneficiary to another person, subject to article 5A(8). Foreign taxes are unaffected. [1] |
| Payment / termination risk | Failure to maintain qualifying conditions ends the relief for the relevant period. Not every job change ends it: notified resumption of qualifying work/business within 12 months can preserve the remaining term. [5] | The 7% tax is payable by the last working day of December. Failure to pay fully removes the regime from that tax year onwards, bringing ordinary worldwide taxation while Greek-resident. [4] | The lump sum is payable by the last working day of December. Non-payment removes the regime from that year onwards. Failure to complete the investment can revoke it retrospectively from initial admission. [1,2] |
| Annual reporting | Ordinary reporting obligations continue, with the approved relief identified in the return. | Greek and foreign income must be declared. | Covered foreign income need not be disclosed in the income-tax return. Greek income and other applicable reporting obligations remain. [2,4] |
Timing and family points that matter
For articles 5A and 5B, a move by 2 July allows an application for the arrival year or the following year; a later move is considered for the following year. The application deadline is separate from proving tax residence. For article 5C, an applicant who started by 2 July but files during the following year is considered for that following year. The old blanket deadlines of 31 March and 31 July should therefore not be used. [2-4]
Under article 5A, unmarried minor children living with the applicant are presumed to share the parent’s tax residence and do not need an extension merely for that purpose. This does not automatically shelter their own foreign income: an application and the additional levy are required if that income is to enter article 5A; otherwise ordinary rules apply. At 18, a child may request inclusion for the parent’s remaining regime term. [2]
The special solidarity contribution was abolished generally for income earned from 1 January 2023. It should no longer be presented as an additional benefit unique to article 5C. Its separate relief from annual deemed living expenditure based on homes and private passenger cars remains relevant. [5,7]
Observations – strengths and weak points
- The three regimes shelter different things. The expatriate regime relieves qualifying Greek-source earnings; the pensioner and investor regimes relieve foreign income. A candidate with both Greek activity and foreign wealth can combine article 5C with either article 5A or article 5B if the conditions of each are met when admission is sought. Articles 5A and 5B cannot be combined or used as an assumed automatic switch from one to the other. [5]
- The investor regime’s blind spot is the absence of a foreign tax credit: tax withheld abroad on dividends or other covered income does not reduce the €100,000. For a portfolio concentrated in high-withholding jurisdictions, the effective cost can substantially exceed that amount. Treaty reductions at source may still help, but must be checked country by country. The pensioner regime does allow a capped foreign tax credit. Certain pensions are taxable only in Greece under the relevant treaty; others, notably some government-service pensions, may remain taxable at source. The 7% is therefore not a universal all-in tax cost. [2,4]
- The investor regime’s quiet advantage is estate planning: the statutory exemption concerns foreign-situated movable property, including qualifying inbound and outbound inheritances and gifts. That is more precise than saying “all assets outside Greece”. Foreign real estate, asset-situs questions and taxes imposed by other countries need separate analysis. Approved relatives can also benefit within the scope of their inclusion. For substantial estates this can outweigh the income-tax arithmetic. [1]
- All three regimes reward administrative discipline. Investors and pensioners must pay by the current December deadline; loss for non-payment is not merely a one-year suspension. Investors must also complete and document the eligible investment: the completion-verification request is due within six months of completion, and failure to complete within three years can unwind admission from its first year. For professionals, loss of conditions affects the relief, but a qualifying job/business transition within the permitted 12-month period is not automatically fatal. A departure from Greece must also be analysed under ordinary residence rules rather than described as automatically creating worldwide taxation. [2,4,5]
- Genuine tax residence is the structural constraint. Article 4 looks at permanent or principal residence, habitual abode and the centre of vital interests; it also contains a more-than-183-days test measured over any twelve-month period, subject to its limited private-stay exception. Treaty tie-breakers matter if another country also claims residence. Non-EU citizens need an appropriate immigration basis for their intended stay and activity. A Golden Visa is one route, not a requirement of the tax regimes; a financially independent-person route may suit some pensioners. Tax approval itself gives no right to work. The tax file and the immigration file must be run in parallel, not sequentially. [6,8]
- Duration asymmetry matters for planning: 7 tax years for professionals against 15 for pensioners and investors. An executive entering article 5C at 50 must plan the end of the seven-year period, around age 57. Simply waiting until then to apply for article 5A may be too late: admission conditions and the window linked to the original transfer of residence remain relevant. Assess a lawful combination at the outset; neither a later family extension nor a return to a regime automatically restarts the clock. [2-5]
A useful arithmetic check: for someone who could qualify for either foreign-income regime, €100,000 equals 7% of approximately €1.43 million of annual foreign income. This is only a starting comparison: foreign credits and withholding, family levies, the investment requirement and estate planning can change the result.
General information note based on articles 4, 5A, 5B and 5C of the Greek Income Tax Code and the official sources below, reviewed as at 18 October 2026. The original comparison and observations have been retained and corrected for the applicable 2026 rules. This document does not constitute individual tax advice; any concrete situation requires its own analysis, including treaty positions between Greece and the countries of source and origin.
Related reading: Greece residency by investment (Golden Visa) 2026–2027 · Swiss lump-sum taxation (2026)
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Official sources
- [1] Law 5313/2026, article 94: amended articles 5A and 5B (Government Gazette).
- [2] AADE A.1147/2026, corrected decision: article 5A procedure, family, payment and investment completion.
- [3] AADE: article 5C application service, current deadlines and A.1096/2026 public-sector extension.
- [4] AADE A.1192/2026: current article 5B procedure, foreign tax credit and December payment.
- [5] AADE article 5C FAQs: scope, job changes, duration and combination with articles 5A/5B.
- [6] AADE: Tax residence for natural persons, article 4 ITC.
- [7] Enterprise Greece: Brief Tax Guide 2025, abolition of the solidarity contribution.
- [8] Ministry of Migration and Asylum: financially independent-person residence category.
