Tax Advantages for Attracting Foreign Professionals and Executives to Greece

Special tax treatment of income for salaried employees and business activity that arises in the country for individuals who transfer their tax residence to Greece.

The taxpayer, an individual, who transfers his tax residence to Greece is subject to taxation, as defined in paragraph 2, for income from salaried employment acquired in Greece, within the meaning of paragraph 1 of Article 5, provided that cumulatively :

a) he was not a tax resident of Greece for the previous five (5) out of the six (6) years before the transfer of his tax residence to Greece,

  1. b)  he transfers his tax residence from a member state of the EU or the EEAor from a state which an administrative cooperation agreement in the

    field of taxation is in force with Greece,

  2. c)  he provides services in Greece in the context of an employmentrelationship within the meaning of paragraph 2 of Article 12, occurred either in a domestic legal entity or in a permanent establishment of a foreign business in Greece, and
  3. d)  he declares that he will remain in Greece for at least two years.

If the taxpayer’s application -in accordance with the procedure provided for in paragraph 3- is accepted, the individual is exempt from income tax and the special solidarity contribution of Article 43A for fifty percent (50%) of his income from employment acquired in Greece during the tax year, subject to the provisions of paragraphs 60 and 61 of Article 72 (cf. paragraph 50 of Article 72). For the submission of the declaration and the payment of the tax of the natural person, Article 67 applies.

For taking up a position that takes place till July 2nd of each year, the application for inclusion in the provisions of this Article is submitted for the year of taking up the position and until the end of year. The application may also be submitted within the next year after taking up the position and is assessed for inclusion in that year.

For taking up a position that takes place after July 2nd of each year, the application for inclusion in the provisions of this Article is submitted for the next year after taking up the position and until the end of year.

Within sixty (60) days from the submission of the application, the Tax Administration examines the application and issues a decision to approve or reject it, depending on whether the conditions of paragraph 1 are met or not.
If the required documents are submitted by March 31st of the year following the submission of the request, the decision to reject the application due to failure to submit the required documents is revoked, the application is re-evaluated by the Tax Administration, and a new decision is issued within sixty (60) days from the submission of the documents.

The individual declares in his application the country in which he had his last tax residence until the submission of his application. The Tax Administration informs the tax authorities of that country regarding the transfer of tax residence of the taxpayer, in accordance with the provisions on international administrative cooperation, as they apply.

The provisions of this Article apply exclusively for the creation of new employment positions.

The provisions of paragraphs 1 to 5 also apply to individuals who transfer their tax residence to Greece in order to engage in individual business activity in Greece. Fifty percent (50%) of their income from business activity acquired in Greece during the tax year is exempt from income tax and the special solidarity contribution of Article 43A for seven (7) consecutive tax years. The application for inclusion in the provisions of this paragraph is submitted in accordance with paragraph 3, and the commencement of work is considered as taking up a position.

By a joint decision of the Minister of Finance and the Director of the Independent Authority for Public Revenue, the deadlines for submitting applications of paragraphs 3 and 7 may be extended, the procedure for inclusion in the provisions of this Article may be determined, including the transfer of tax residence, the competent authority for submitting, examining, and approving the application, the documents accompanying the application, the documents for proving compliance with the conditions of this Article, as well as any other necessary matter or detail for the implementation of the provisions of this Article.

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