Greece

Personal and business taxation in Greece

Documentary position as at 5 October 2026. The reference points below are based on the texts published in the Official Gazette of the Hellenic Republic (Εφημερίδα της Κυβερνήσεως, “ΦΕΚ”), downloaded from the official storage of the National Printing Office, and on the France–Greece tax treaty and the French administrative guidance on it. The website of the Greek tax administration (ΑΑΔΕ) and that of the Ministry of Finance could not be consulted directly; their decisions are cited in the version published in the ΦΕΚ. Amounts are expressed in euros.

1. Tax year, taxpayers and source of income

1. Greek income tax is governed by the Income Tax Code (Κώδικας Φορολογίας Εισοδήματος, “ΚΦΕ”), enacted by Law 4172/2013 published in ΦΕΚ A’ 167 of 23 July 2013. In the absence of a downloadable official consolidated version, each rule is read in the original text and then in the amending law identified. S01

2. Under Article 8 of the ΚΦΕ, the tax year (φορολογικό έτος) coincides with the calendar year. Legal persons and entities keeping double-entry books may close their financial year on 30 June, and a resident company more than 50% held by a foreign entity may adopt that entity’s financial year, provided that the financial year does not exceed twelve months. S01

3. Article 3 of the ΚΦΕ lays down the charging rule: a taxpayer who is tax resident in Greece is taxed on his or her worldwide income, whereas a non-resident is taxed only on Greek-source income earned during the year. S01

4. Article 5 of the ΚΦΕ lists Greek-source income, in particular salaries and business income relating to an activity carried on in Greece, income from and gains on immovable property situated in Greece, dividends from resident legal persons, and interest and royalties paid by a resident or by a permanent establishment in Greece. Any other income is foreign-source income (§ 2), a concept that defines the scope of the regimes under Articles 5A and 5B. S01

2. Individual residence, arrival and departure

5. Article 4 § 1 of the ΚΦΕ, as worded by Law 4646/2019, treats as tax resident in Greece an individual who has his or her permanent or principal residence, habitual abode or centre of vital interests there, that is to say his or her personal and economic ties. The 2013 text referred to “personal or economic or social” ties; the 2019 law refers to “personal and economic” ties. S01S03

6. Under Article 4 § 2, as worded in 2019, an individual present in Greece for more than 183 days, cumulatively, during any twelve-month period becomes resident from the first day of presence. This test does not apply to persons present exclusively for tourist, medical, therapeutic or similar private purposes for a stay not exceeding 365 days, including short stays abroad. These amendments have applied since the publication of Law 4646/2019 in ΦΕΚ A’ 201 of 12 December 2019. S03

7. The ΑΑΔΕ decisions relating to Articles 5A and 5B state that the acquisition of tax residence is assessed exclusively under Article 4 of the ΚΦΕ and is a question separate from admission to the alternative taxation regime. The deadline for applying for these regimes is set independently and does not depend on the date on which the conditions of Article 4 are met. S11S13

8. On departure, Article 66A of the ΚΦΕ, introduced by Law 4714/2020 transposing Directive 2016/1164, taxes the unrealised gain on assets transferred out of Greece, in particular on a transfer of residence. Its scope covers legal persons, entities and permanent establishments (§ 1), for transfers made since 1 January 2020. No exit taxation of individuals’ unrealised gains was identified in the texts consulted, this finding being limited to those texts. S04

3. Income tax for residents: 2025 and 2026 scales

9. Article 15 § 1 of the ΚΦΕ sets a single scale for salaries, pensions and income from business activity (επιχειρηματική δραστηριότητα). For income for the years 2020 to 2025, the applicable scale is the one resulting from Article 6 of Law 4646/2019, applicable to income earned on or after 1 January 2020; subsequent adjustments, in particular for young taxpayers, have not been reconstructed in the absence of an official consolidated version. S03

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10. The 2025 reform (Law 5246/2025, ΦΕΚ A’ 198 of 11 November 2025) has been passed and published. Its Article 3 replaces Article 15 § 1 of the ΚΦΕ and its Article 47 § 3 provides that it applies to income earned from the 2026 tax year onwards. The basic scale becomes the following. S08

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11. The new text varies the rates according to the number of dependent children within the meaning of Article 11 of the ΚΦΕ. The rate of the second band is reduced to 18% with one child, 16% with two children and 9% with three children; it is nil, like that of the first band, from four children. The rate of the third band is reduced to 24%, 22%, 20% and 18% for one to four children, then lowered by two points for each additional child beyond four. S08

12. For young taxpayers, the rate of the first two bands, on taxable income up to €20,000, is nil up to the age of 25 and 9% from 26 to 30, unless the four-children rule applies, in which case it is nil. This rule concerns only the first two bands. S08

13. Article 15 § 6 of the ΚΦΕ, added by Law 4646/2019 for income and expenditure from 1 January 2020, requires proof of expenditure settled by electronic means of payment amounting to 30% of actual salary, pension and business income, up to a limit of €20,000 of expenditure. The shortfall is multiplied by 22% and added to the tax computed under the scale. This factsheet has not checked subsequent amendments to this mechanism. S03

4. Regimes for new residents: Articles 5A, 5B and 5Γ

14. Three optional regimes target persons who transfer their tax residence to Greece. Their statutory numbering is as follows: Article 5A establishes the €100,000 flat-rate taxation of investors’ foreign income, Article 5B the 7% taxation of pensioners’ foreign income, and Article 5Γ the 50% exemption of the employment and business income of persons who come to work in Greece. S03S04S05

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15. Article 5A, introduced by Law 4646/2019 and reproduced in full in its version as amended by Article 94 of Law 5313/2026 (ΦΕΚ A’ 102 of 25 June 2026), requires, cumulatively, that the taxpayer has not been a Greek resident for seven of the eight years preceding the transfer and that he or she invests, directly, through a relative or through a legal person in which he or she holds a majority interest, at least €500,000 in immovable property, businesses, securities or shares in companies established in Greece, the investment having to be made within three years of the application. S03S09

16. The investment condition is not required of a person who has obtained and holds a residence permit for investment activity within the meaning of Article 16 of Law 4251/2014. The beneficiary’s Greek-source income remains taxed under the general rules of the ΚΦΕ. S09S18

17. The beneficiary pays, each year, a flat-rate tax of €100,000 whatever the amount of his or her foreign income. He or she may apply for the regime to be extended to a relative within the meaning of Article 2 (spouse, ascendants and descendants in the direct line), at the time of admission or subsequently since Law 5222/2025, in return for €20,000 per relative. Foreign tax paid on the income covered cannot be credited against any Greek tax liability. S01S07S09

18. Payment of the flat-rate tax in a single instalment, set at the end of July in the 2019 wording, is postponed to the last working day of December by Law 5313/2026. Payment within thirty days of approval for the first year is abolished and the 31 March deadline for the application is removed from the statutory text, the ΑΑΔΕ being responsible for setting the deadline. S03S09

19. The regime runs from the first year for which the application is filed and ends after fifteen tax years, with no possibility of extension. For a relative admitted subsequently, it runs for the years remaining until the end of the fifteen years. S07S09

20. In the wording reproduced by Law 5313/2026, Article 5A § 5 provides for two grounds for exit: failure to pay the full tax for a year, which entails taxation of worldwide income under the ordinary rules from that year, and a finding, after three years, that the investment has not been made, which causes the regime to lapse from the year of admission. In both cases, the tax then due on foreign income cannot be less than €100,000 per year, after deduction of the flat-rate amounts paid. This second ground appears neither in the 2019 text nor in Law 5222/2025, and Article 94 of Law 5313/2026 does not amend § 5; the law that introduced it has not been identified. S09

21. Payment of the flat-rate amount discharges the tax liability on foreign income. Article 5A § 8, amended by Law 5222/2025 and then restated in 2026, also exempts from Greek inheritance and gift tax movable property situated abroad that the beneficiary receives, as well as his or her own movable property situated abroad transferred to a third party, this second rule applying to estates opened since 1 January 2020. S07S09

22. Decision A.1147/2026 of the Governor of the ΑΑΔΕ (ΦΕΚ B’ 4431 of 20 July 2026, corrected in ΦΕΚ B’ 4838 of 4 August 2026) sets out the procedure. A person who arrived no later than 2 July may apply for the regime for the year of arrival or the following year, and a person who arrived after that date for the following year; the application is filed no later than 30 September of the year concerned with the ΚΕΦΟΔΕ of Attica or, once it becomes operational, that of Thessaloniki, together with proof of the transfer of the minimum investment amount to an account opened in Greece. S11S12

23. Since its publication, this decision applies to applications pending on 25 June 2026, the date on which Article 94 of Law 5313/2026 entered into force, and to assessments for the year 2026 not yet paid. The previous procedure resulted from Decision A.1036/2020 (ΦΕΚ B’ 624 of 26 February 2020), which provided for an application by 31 March. S10S11

24. Article 5B, introduced by Law 4714/2020 and restated in its 2026 version, subjects a pensioner admitted to the regime to a separate tax of 7% on all of his or her foreign-source income, and not on pensions alone. It requires that the person has not been a Greek resident for five of the six preceding years and comes from a State with which an agreement on administrative cooperation in tax matters is in force. The tax is paid on the last working day of December since 2026. S04S09

25. The regime lasts fifteen years at most and does not affect the application of tax treaties (§ 8). According to Decision A.1192/2026 (ΦΕΚ B’ 5767 of 24 September 2026), a person who arrived no later than 2 July may apply for the regime for the year of arrival or the following year, and a person who arrived after that date for the following year; the application is filed no later than 31 October of the year concerned, the decision being taken within sixty days and no later than the last working day of December. This decision, which replaces Decision A.1217/2020, gives effect to admission for the year of the application, whereas Article 5B § 4 makes application begin in “the following tax year”; how these two wordings fit together has not been resolved here. S09S13

26. Article 5Γ, introduced by Law 4758/2020 for years beginning on or after 1 January 2021, exempts from income tax and from the special solidarity contribution 50% of the salary earned in Greece by a person who transfers his or her residence, for seven years at most. The conditions are summarised in the table above; the employment must be exercised with a Greek entity or a permanent establishment in Greece. § 7 extends the 50% exemption to the profits of an individual business activity carried on in Greece. S05S07

27. Law 5222/2025 (ΦΕΚ A’ 134 of 28 July 2025) repealed § 6 of Article 5Γ, which reserved the regime for the creation of new posts, including for applications pending at its publication. In the wording reproduced by that law, Article 5Γ § 3 provides that, where employment begins no later than 2 July, the application is made for the year in which employment begins until the end of that year, or during the following year, in which case it applies to that following year, and that, where employment begins later, it applies to the following year. S05S07

28. Law 5313/2026 adds to Article 43 of the ΚΦΕ a rate of 5% on carried interest paid to employees of entities established in Greece serving related managers of alternative investment funds, where the employee has transferred his or her residence to Greece under Article 5Γ and the entity incurs at least €3,000,000 of annual expenditure in Greece. This rule applies to years beginning on or after 1 January 2026, for seven years at most. S09

5. Non-residents and withholding taxes

29. A non-resident is taxable in Greece only on Greek-source income within the meaning of Article 5 of the ΚΦΕ. Article 62 subjects to withholding dividends, interest, royalties, fees for technical, management and consulting services paid to an individual, certain group insurance benefits and an individual’s gain on immovable property; its § 3 also subjects to withholding fees for technical, management or consulting services received by a non-resident legal person. S01

30. The domestic withholding rates are set out in Article 64 § 1 of the ΚΦΕ. The rate on dividends, initially 10%, was reduced to 5% by Law 4646/2019 for income earned since 1 January 2020; the other rates in the table come from the 2013 text, without checking for any subsequent amendments. S01S03

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31. Article 63 of the ΚΦΕ exempts from withholding dividends paid to a parent company covered by Directive 2011/96 that has held at least 10% of the capital for at least 24 months and is resident in a Member State and subject to tax without an option. In the wording resulting from Law 4646/2019, Article 63 § 2 exempts from withholding interest and royalties between associated companies of the Union where the holding of at least 25% has been held for 24 months. S01S03

32. To obtain the treaty rates, Article 28 § 2 of the France–Greece treaty provides that the resident of France presents a certificate of tax residence certified by the French tax administration, unless otherwise provided by the competent authorities. The Greek arrangements for refund or for direct application at source have not been reconstructed. S23

6. Investment income and capital gains of individuals

33. Article 40 of the ΚΦΕ taxes the investment income of individuals at flat rates separate from the scale. Dividends are taxed at 5% since Law 4646/2019 for income earned on or after 1 January 2020; in the 2013 text, interest is taxed at 15% and royalties at 20%. S01S03

34. Income from immovable property is taxed separately under the scale in Article 40 § 4. Law 5246/2025 replaced that scale for income earned from the year 2026 onwards. The amending text replaces the band from €12,001 to €35,000, taxed at 35%, with a band from €12,000.01 to €24,000 taxed at 25%, inserts a new band and replaces the band beginning at €35,001 with a band over €36,000. S08

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35. Law 5246/2025 also extends the temporary exemption of rents from dwellings of up to 120 m², increased by 20 m² per dependent child of the tenant beyond two, under leases of at least three years concluded between 8 September 2024 and 31 December 2026, for the first 36 months, subject to conditions relating to the dwelling having previously been vacant or previously used for short-term letting. Under Article 47 § 4 of that law, these adjustments apply only to leases concluded on or after its publication, on 11 November 2025; leases concluded before then remain governed by the previous wording of Article 72 § 91, not reconstructed here. S08

36. The gain on the disposal of immovable property realised by an individual outside a business activity falls under Article 41 of the ΚΦΕ, with a 15% withholding provided for in Article 64 § 1 (στ). The application of Article 41 is suspended until 31 December 2026 by Article 72 § 33 of the ΚΦΕ, as worded by Article 90 of Law 5162/2024 (ΦΕΚ A’ 198 of 5 December 2024). S01S14

37. Gains on the disposal of securities (shares, holdings, bonds, derivatives) realised outside a business activity fall under Article 42 of the ΚΦΕ. Article 43, as reproduced in full by Law 5313/2026, taxes them at the rate of 15%, reduced to 5% for the gains referred to in Article 42A § 2. The exemptions for listed securities and Article 42A have not been checked. S01S09

7. Companies: residence, rates, holdings, Pillar Two

38. Under Article 4 § 3 of the ΚΦΕ, a legal person or entity is resident in Greece if it was incorporated under Greek law, if its registered office is in Greece or if its place of effective management is situated there during the year. § 4 assesses that place having regard, in particular, to day-to-day management, strategic decisions, general meetings, the keeping of the books, board meetings and the residence of its members. S01

39. The corporate income tax rate, set at 26% in 2013 and then at 24%, a rate limited to income for 2019 and 2020 by Law 4799/2021, is 22% for income for the years 2021 onwards under Article 58 § 1 (α) of the ΚΦΕ, as worded by Article 120 of Law 4799/2021. Credit institutions falling under Article 27A are taxed at 29%. S01S03S06

40. Article 48 of the ΚΦΕ, in its 2013 text, exempts intra-group dividends received by a resident legal person holding at least 10% of the capital or voting rights for at least 24 months, where the distributing company is not established in a non-cooperative State within the meaning of Article 65; a provisional exemption against a guarantee is possible before the period expires. Its subsequent amendments have not been consolidated. S01

41. Article 48A, introduced by Law 4646/2019 for income earned on or after 1 July 2020, exempts the gain on the disposal of securities realised by a resident legal person where the company whose securities are disposed of is covered by Directive 2011/96, is resident in a Member State and is taxed there without an option, and the holding of at least 10% has been held for 24 months. Expenses relating to the holding disposed of are then not deductible. S03

42. The controlled foreign companies regime of Article 66, rewritten by Law 4607/2019, covers in particular a foreign entity more than 50% held whose actual tax is lower than the difference between the notional Greek tax and the tax actually paid, where more than 30% of its pre-tax result falls within the listed categories of passive income. S15

43. Law 5100/2024 (ΦΕΚ A’ 49 of 5 April 2024) transposes Directive 2022/2523 on global minimum taxation. It covers large-scale multinational and domestic groups whose consolidated revenue reaches at least €750,000,000 in at least two of the four preceding financial years and applies a minimum effective rate of 15%. S16

44. Article 12 of that law establishes a domestic top-up tax (εγχώριος συμπληρωματικός φόρος) payable by constituent entities established in Greece. Under Article 69, Part B of the law applies to financial years beginning on or after 31 December 2023, and Articles 13 to 15 (undertaxed profits rule) on or after 31 December 2024, subject to a special regime. S16

8. VAT (ΦΠΑ)

45. Value added tax (Φόρος Προστιθέμενης Αξίας, “ΦΠΑ”) is governed by the VAT Code enacted by Law 5144/2024 (ΦΕΚ A’ 162 of 11 October 2024). Its Article 26 § 1, in the wording reproduced in full by Article 11 of Law 5246/2025, sets the following rates. S19S08

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46. The new Article 26 § 4A reduces the ΦΠΑ rates by 30% on the islands of the North Aegean region, of the regional unit of Evros (Samothrace) and of the Dodecanese whose population does not exceed 20,000 inhabitants according to the latest census. Under Article 47 § 5 of Law 5246/2025, this measure applies from 1 January 2026. The reduction applies neither to tobacco products nor to means of transport. S08

47. Article 44 of the VAT Code allows taxable persons whose turnover for the previous year does not exceed €10,000 excluding tax to be relieved of filing and payment obligations. This scheme does not apply, in particular, to taxable persons not established in Greece or to supplies of new means of transport; the option must be exercised within thirty days of the beginning of the year. S19

48. Article 70 of the VAT Code, amended by Article 12 of Law 5246/2025, extends until 31 December 2026 the suspension, at the request of the builder, of VAT on new buildings, which are then subject to transfer tax. S08

9. Real estate: transfer tax, ENFIA and special tax

49. Law 5219/2025 (ΦΕΚ A’ 130 of 18 July 2025) codified real estate and inheritance taxation in a Property Taxation Code (Κώδικας Φορολογίας Περιουσίας), applicable since its publication. This code brings together the valuation of immovable property, the unified annual property tax (ENFIA), the special real estate tax, transfer tax and inheritance and gift tax. S20

50. Under Article 22 of that code, any transfer for consideration of ownership of immovable property or of a right in rem over immovable property is subject to transfer tax (φόρος μεταβίβασης) on its value. Article 24 places the tax on the acquirer. S20

51. Article 27 § 1 sets the rate at 3% of the taxable value. It is reduced to one quarter in the case of a partition in kind between co-owners or the allocation of immovable property to the partners on the dissolution of certain companies, and to one half, in particular, in the case of an exchange of immovable property of equal value or of expropriation. Article 27 § 5 adds an additional tax of 3% of the amount of the tax for the benefit of municipalities. S20

52. ENFIA (Ενιαίος Φόρος Ιδιοκτησίας Ακινήτων), established from 2014 by Law 4223/2013, is now governed by Articles 8 et seq. of the 2025 code. It is due each year on rights in rem (full ownership, bare ownership, usufruct, right of habitation, right of superficies) held on 1 January over immovable property situated in Greece, Article 8 making no distinction according to the nationality or residence of the holder. S02S20

53. For an individual, the tax comprises a main tax computed property by property according to location, use, age and other coefficients, which this factsheet does not reconstruct, and a surcharge. For a legal person, it comprises the main tax and a supplementary tax of 5.5‰ of the value of the rights, reduced to 1‰ for immovable property used for the business of the enterprise and to 3.5‰ for immovable property that certain non-profit entities do not use themselves. S20

54. For individuals, section Γ of Article 11 adds a tax on the value of each right according to the following scale, where the total value of the real estate holdings exceeds €300,000. Section Ε increases the tax of individuals by 5% for holdings up to €650,000, by 10% up to €800,000, by 15% up to €1,000,000 and by 20% above that, this surcharge applying only if the total value exceeds €500,000. S20

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55. Law 5246/2025 reduces by 50% the 2026 ENFIA of individual tax residents for their principal residence situated in a locality of 1,500 inhabitants or fewer, or 1,700 in certain designated regions, in particular border regions, excluding Attica except for its islands, where the value of the residence does not exceed €400,000; from 2027, these rights are exempt. S08

56. Article 18 of the 2025 code subjects legal persons and entities holding rights of full ownership, bare ownership or usufruct over immovable property situated in Greece to an annual special tax of 15% of its value. The text excludes, in particular, listed companies and companies carrying on a commercial, industrial or service activity in Greece whose receipts from that activity exceed their real estate receipts; the other exclusions and their documentary conditions have not been detailed. S20

10. Wealth and residence by investment

57. The 2025 Property Taxation Code, as read, comprises ENFIA, the special real estate tax, transfer tax and inheritance and gift tax, without any general tax on net wealth. No wealth tax on individuals was identified in the texts consulted; this finding is limited to those texts and does not result from an exhaustive review of the legislation. S20

58. The real estate investor residence permit, known as the “Golden Visa”, falls under Article 100 of the Immigration Code (Law 5038/2023), replaced by Article 64 of Law 5100/2024. The acquisition threshold is €800,000 in Attica, in the regional unit of Thessaloniki, in the regional units of Mykonos and Thira (Santorini and attached islands) and on islands with more than 3,100 inhabitants, and €400,000 elsewhere, for a single property of at least 120 m² of main surface area where it is built. S16S17

59. The threshold is €250,000 for the conversion into housing of a building with another use, in particular industrial, and for the restoration of a listed building. Transitional provisions allowed an investment to be completed under the former rules until 31 December 2024, subject in particular to payment of a 10% deposit or signature of a preliminary contract no later than 31 August 2024, in accordance with the terms of the text. Any amendments after 2024 have not been researched. S16

60. For the exemption from the investment condition, Article 5A of the ΚΦΕ refers to the residence permit for investment activity under Article 16 of Law 4251/2014 “as in force”. The correspondence between that reference and the residence permit under Article 100 of the Immigration Code has not been established from an official source; it is a matter of administrative practice and constitutes a limit of this factsheet. S09S17S18

11. Inheritances and gifts

61. Inheritance tax is governed by Articles 54 et seq. of the Property Taxation Code. Under Article 55, property of any kind situated in Greece is taxable, whatever the nationality and domicile of the deceased, as is movable property situated abroad belonging to a Greek national, wherever domiciled, or to a foreign national domiciled in Greece. S20

62. Article 75 § 2 (γ) exempts movable property situated abroad of a Greek national established outside Greece for at least ten consecutive years, except for public officials, military personnel and employees of businesses established in Greece who are settled abroad by reason of their duties. Article 83 allows foreign tax paid on movable property situated abroad to be credited, up to the corresponding Greek tax. S20

63. Article 78 divides beneficiaries into three categories. Category A includes in particular the spouse or partner under a cohabitation agreement, children, grandchildren and parents. Category B includes in particular descendants beyond the second degree, ascendants beyond the first degree, brothers and sisters, collateral relatives in the third degree and close relatives by marriage; category C includes any other person. S20

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64. The scale is published in table form in ΦΕΚ A’ 130/2025; its bands and rates were read on the printed page of the Official Gazette, the text extraction of the table being illegible. Article 79 § 2 reduces by 10% the tax payable by an heir with a disability of at least 67%. S20

65. Under Article 98, gifts and parental endowments (γονική παροχή) are subject to the same categories and scales, after deduction of the tax relating to earlier gifts aggregated and of foreign tax. However, a gift or parental endowment of any property to a person in category A, as well as a gift of sums of money transferred through a financial institution, is taxed at the rate of 10% after a single allowance of €800,000 and is not aggregated with the estate between the same persons. S20

66. Other gifts of sums of money are taxed separately at the rate of 10% for category A, 20% for category B and 40% for category C. The specific exemptions, including those for the acquisition of a first residence (Articles 76 and 96), are not detailed. S20

67. A beneficiary of the Article 5A regime benefits from an exemption from Greek inheritance and gift tax on movable property situated abroad, whether he or she receives it or transfers it to a third party. The Article 5B regime contains no equivalent exemption in the texts read. S09

68. The 2022 France–Greece tax treaty covers only taxes on income. No France–Greece treaty on inheritances and gifts was identified in the list of treaties published by the DGFiP, this finding being limited to that list. S23S27

12. France–Greece treaty and exchange of information

69. The France–Greece tax treaty on taxes on income was signed in Athens on 11 May 2022, together with a protocol. According to the BOFiP, it entered into force on 30 December 2023 and applies, in respect of taxes withheld at source, to taxable events occurring on or after 1 January 2024 and, in respect of other taxes on income, to years or financial years beginning on or after that date. S23S26

70. It replaces the treaty of 21 August 1963, which ceases to have effect from the application of the new treaty; the DGFiP still publishes the 1963 text and its consolidated version as modified by the multilateral convention, which now concern only earlier years. On the Greek side, the treaty was ratified by Law 4984/2022 (ΦΕΚ A’ 202 of 25 October 2022). S22S24S25S26

71. The taxes covered include, for Greece, the income tax on individuals, including the special solidarity contribution, and the income tax on legal persons; for France, in particular, income tax (impôt sur le revenu), corporate income tax (impôt sur les sociétés) and the generalised social contributions (contributions sociales généralisées) and contributions for the repayment of the social debt (contributions pour le remboursement de la dette sociale). The text used is the one published by the DGFiP, which is not the authentic text published in the Journal officiel. S23

72. Article 4 § 2 resolves the position of individuals resident in both States by reference to the permanent home, the centre of vital interests, the habitual abode, nationality and then mutual agreement. Dual-resident companies are resident in the State in which their place of effective management is situated. S23

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73. Article 17, according to the BOFiP, covers pensions paid under social security legislation. A French private or social security pension paid to a resident of Greece is therefore taxable only in Greece, where applicable at the 7% rate of Article 5B; by contrast, a French government pension falls under Article 18 § 2 and remains taxable in France, unless the beneficiary has Greek nationality without French nationality. Paragraph 6 of the protocol allows Article 18, on request, to be applied to periods beginning on or after 1 January 2015. S23S26

74. Article 21 provides for the elimination of double taxation. In France, income taxable in Greece is taken into account and gives entitlement to a tax credit equal either to the corresponding French tax or, for profits and gains subject to corporate income tax (Articles 7 and 13 § 2), dividends, interest, royalties, gains under §§ 1 and 4 of Article 13, crew remuneration (Article 14 § 3), directors’ fees and income of artistes, sportspersons and models (Article 16 §§ 1 and 2), to the tax paid in Greece up to the amount of the French tax. In Greece, the French tax is deducted from the Greek tax up to the fraction corresponding to the income taxable in France. S23

75. Articles 24 and 25 of the treaty provide for the exchange of information that is foreseeably relevant for taxes of every kind and for assistance in the collection of tax claims. Law 4428/2016 (ΦΕΚ A’ 190 of 2016) also ratified the declaration, signed in Berlin on 29 October 2014, of Greece’s accession to the multilateral competent authority agreement on the automatic exchange of financial account information. S21S23

13. Illustrative cases and limits of application

76. Case 1 — a French executive who has not been resident in Greece for more than six years takes up a post on 1 March 2026 with the Athens subsidiary of a group and settles there with his family. He becomes a Greek resident under Article 4 of the ΚΦΕ and may apply for the Article 5Γ regime for 2026, the job-creation condition having been repealed in 2025; half of his Greek salary is then exempt and the other half taxed under the 2026 scale as varied according to the number of children. S05S07S08S23

77. Case 2 — a retired woman of French nationality receiving a pension from the general scheme and a State civil service pension settles in Crete. Subject to the conditions of Article 5B and to an application filed within the deadline set by Decision A.1192/2026, her social security pension, taxable only in Greece under Article 17 of the treaty, may bear the 7% tax; her government pension remains taxable in France under Article 18 § 2. S09S13S23S26

78. Case 3 — a French entrepreneur who has not been resident in Greece for more than eight years acquires €600,000 of shares in Greek companies and immovable property in Athens, then applies for the Article 5A regime. He would pay €100,000 per year on his foreign income, plus €20,000 per relative admitted, his Greek income remaining taxed under the ordinary rules; if the investment were not completed by the end of three years, the admission would lapse from the outset. The French consequences of departure are not analysed. S09S11

79. Case 4 — a French company with no activity in Greece acquires an apartment in Athens in order to let it. The acquisition bears the 3% transfer tax and the additional municipal tax, except in the case of an acquisition from the builder of a new building subject to VAT, in the absence of the suspension provided for in Article 70 of the VAT Code; the company is liable for ENFIA, including the supplementary tax of 5.5‰, and, in the absence of an established exclusion, for the annual special tax of 15% of the value of the property. The rents are taxable in Greece under Article 6 of the treaty. S08S20S23

80. Limits of application: this factsheet is based on the texts published in the ΦΕΚ, without an official consolidated version of the ΚΦΕ, the VAT Code or the Property Taxation Code; unidentified amendments may affect certain rates, in particular those in Article 64 and the Article 48 regime. The websites of the ΑΑΔΕ, the Ministry of Finance and the Parliament refused access; implementing circulars, the reductions under Article 16, social security contributions and the taxable values of immovable property are not covered. Negative statements, in particular the absence of a wealth tax and of exit taxation of individuals, are limited to the texts consulted, and the factsheet does not constitute personalised advice. S01S20S23

Sources

• S01: Law 4172/2013, Income Tax Code (ΚΦΕ), original text, ΦΕΚ A’ 167 of 23 July 2013
• S02: Law 4223/2013, ENFIA and amendment of Article 4 of the ΚΦΕ, ΦΕΚ A’ 287 of 31 December 2013
• S03: Law 4646/2019, ΦΕΚ A’ 201 of 12 December 2019 (Articles 1, 2, 6, 7, 20 to 24 and 66)
• S04: Law 4714/2020, ΦΕΚ A’ 148 of 31 July 2020 (Article 5B and Article 66A of the ΚΦΕ)
• S05: Law 4758/2020, ΦΕΚ A’ 242 of 4 December 2020 (Article 5Γ of the ΚΦΕ)
• S06: Law 4799/2021, ΦΕΚ A’ 78 of 18 May 2021 (Article 120: corporate income tax rate)
• S07: Law 5222/2025, ΦΕΚ A’ 134 of 28 July 2025 (Article 206: Articles 5A, 5B and 5Γ of the ΚΦΕ)
• S08: Law 5246/2025, tax reform, ΦΕΚ A’ 198 of 11 November 2025
• S09: Law 5313/2026, ΦΕΚ A’ 102 of 25 June 2026 (Articles 94 and 96: Articles 5A, 5B, 42 and 43 of the ΚΦΕ)
• S10: Decision A.1036/2020, Article 5A procedure, ΦΕΚ B’ 624 of 26 February 2020
• S11: Decision A.1147/2026 of the Governor of the ΑΑΔΕ, Article 5A procedure, ΦΕΚ B’ 4431 of 20 July 2026
• S12: Correction of Decision A.1147/2026, ΦΕΚ B’ 4838 of 4 August 2026
• S13: Decision A.1192/2026 of the Governor of the ΑΑΔΕ, Article 5B procedure, ΦΕΚ B’ 5767 of 24 September 2026
• S14: Law 5162/2024, ΦΕΚ A’ 198 of 5 December 2024 (Article 90: suspension of Article 41 of the ΚΦΕ)
• S15: Law 4607/2019, ΦΕΚ A’ 65 of 24 April 2019 (Article 12: Article 66 of the ΚΦΕ, controlled foreign companies)
• S16: Law 5100/2024, global minimum taxation (Directive 2022/2523), ΦΕΚ A’ 49 of 5 April 2024
• S17: Law 5038/2023, Immigration Code, ΦΕΚ A’ 81 of 1 April 2023 (Article 100)
• S18: Law 4251/2014, former Immigration Code, ΦΕΚ A’ 80 of 1 April 2014 (Article 16)
• S19: Law 5144/2024, VAT Code (ΦΠΑ), ΦΕΚ A’ 162 of 11 October 2024
• S20: Law 5219/2025, Property Taxation Code (Κώδικας Φορολογίας Περιουσίας), ΦΕΚ A’ 130 of 18 July 2025
• S21: Law 4428/2016, ratification of the multilateral agreement on the automatic exchange of financial account information, ΦΕΚ A’ 190 of 2016
• S22: Law 4984/2022, ratification of the Greece–France tax treaty, ΦΕΚ A’ 202 of 25 October 2022
• S23: DGFiP, France–Greece treaty of 11 May 2022 and protocol (taxes on income)
• S24: DGFiP, France–Greece treaty of 21 August 1963
• S25: DGFiP, consolidated version of the 1963 France–Greece treaty as modified by the multilateral convention
• S26: BOFiP, BOI-INT-CVB-GRC of 11 September 2024, tax treaty between France and Greece
• S27: DGFiP, list of international tax treaties (Greece section)