The Framework for Family Offices under Article 71H of the Greek Income Tax Code

The operation of special-purpose family wealth management companies (Family Offices) now constitutes a fundamental tool for individuals with tax residence in Greece who seek centralized, efficient, and institutionally transparent management of their assets.

The special tax regime for Family Offices, applicable from tax year 2021 onwards, was introduced by paragraph 1 of Article 25 of Law 4778/2021 (Government Gazette A’ 26/19-02-2021) and was subsequently amended by paragraph 3 of Article 211 of Law 5222/2025 (Government Gazette A’ 134/28-07-2025).

Key Points of the Regulation

1. Possibility of Establishment by Non-Resident Taxpayers

The establishment of a special-purpose family wealth management company (Family Office) is permitted either directly by individuals and their family members or through a legal entity in which those individuals hold a majority participation.

The establishment of a Family Office in Greece is now also permitted by individuals who do not have tax residence in Greece, without triggering a deemed transfer of tax residence or place of effective management.

Example: Mr. A., a tax resident of Switzerland with significant interests in Europe and the Middle East, chooses to establish a Family Office in Athens in order to centralize the management of his investments. The new provision ensures that the establishment of the new company will not result in a change to his tax residence, thereby limiting tax risks..

2. Reduction of Minimum Annual Operating Expenses

The required minimum annual operating cost is reduced from €1,000,000 to €500,000, making the establishment and operation of a Family Office more accessible and feasible for smaller-scale asset structures.

Example: A family with a medium-sized investment portfolio (e.g. three properties in Europe, two corporate participations, one philanthropic foundation), which could not justify operating costs exceeding €1,000,000 per year, may now operate a Family Office with documented expenses of €500,000.

3. Revenue Calculation Method – "Cost Plus 7%"

The new regulation maintains the core principle of the “cost plus profit margin” method, whereby the gross revenues of special-purpose family wealth management companies are determined on the basis of documented operating expenses increased by 7%.

However, a significant deviation from the previous provision is the express stipulation that, where the company’s actual revenues as recorded in its accounting books exceed the amount calculated under the “cost plus 7%” method, the higher book revenues shall be taken into account.

In other words, the “cost plus” method now operates as a minimum taxable income threshold rather than a binding maximum cap, as was previously the case.

This allows greater flexibility in the tax treatment of revenues while simultaneously ensuring proper documentation and tax compliance, particularly in transactions with related entities, where specific transfer pricing documentation is required.

This amendment has contributed to improved tax transparency and to aligning the institutional framework with international standards.

Example: Family Office "X Ltd" incurs total operating expenses of €500,000 (salaries, rent, accounting services, external consultants).

Under the “cost plus 7%” method: Minimum gross income = €500,000 + 7% = €535,000

Only the profit margin of €35,000 is subject to tax at the corporate income tax rate of 22% (i.e. 7% of expenses).

If the company invoices a related holding company €600,000, the higher book revenue (€600,000) is taken into account.

Assessment: The “cost plus 7%” method means that the minimum gross income is determined as total operating expenses plus a 7% profit margin.

Taxable income is the profit, namely 7% of expenses (€35,000).

If the revenues declared in the accounting books are higher (€600,000), then €600,000 is taken into account instead of €535,000.

Taxation is applied on revenues minus expenses; therefore, if expenses amount to €500,000 and revenues to €600,000, the taxable profit is €100,000 (and not €35,000).

Furthermore, since invoicing is made to a related party, transfer pricing documentation may also be required pursuant to Articles 50–51 of the Income Tax Code.

4. Obligation to Employ Five Employees in Greece

The special-purpose company (Family Office) is required to employ at least five employees in Greece within 12 months from its establishment. This requirement ensures that Family Offices have genuine economic substance in Greece and operate not merely as tax vehicles, but as active administrative structures contributing to local employment and the economy.

5. Provision of Services to Trusts and Foreign Companies without Tax Residence in Greece

It is now explicitly stated that providing services to foreign entities, trusts, or holding companies does not result in a shift of their tax residency to Greece.

In all cases, the exclusive purpose of special-purpose companies is the administration and management of assets and investments held directly or indirectly.

Example: The Greek family office company “A” provides reporting and management services to a foreign trust owned by its founder. Under the new provision, the trust remains a tax resident abroad, without any risk of acquiring tax residence in Greece.