The Greek Non-Dom Tax Regime
- Tax Experts
- Jun 6
- 2 min read
August 27, 2024
Over the past few years, Greece has introduced a series of targeted tax incentives to attract foreign individuals — especially retirees — to relocate and establish tax residency in the country. Among these, the Greek non-dom tax regime, originally introduced by Law 4646/2019, has proven particularly significant.
Initially effective for the 2020 tax year, the Non-Dom regime allowed eligible individuals to benefit from favorable tax treatment by submitting an application by March 31, 2020. Since then, the regime has undergone refinements, and its scope has expanded, particularly in relation to foreign-source pensions.
In mid-2020, the Ministry of Finance released a Tax Bill for public consultation that complemented the existing Non-Dom framework. Today, this legislation is fully implemented and forms a core part of Greece’s strategy to attract pensioners from abroad.
Key Provisions for Foreign Pensioners
Under the now-effective legislation, foreign-source pensions may be subject to alternative Non-Dom taxation, provided the individual transfers their tax residency to Greece and meets the following conditions:
They were not a Greek tax resident for five out of the six years preceding the transfer.
They transfer their tax residency from a country that has a tax administrative cooperation agreement with Greece.
If eligible, the taxpayer is taxed at a flat rate of 7% on their foreign-source pension income, which exhausts their Greek income tax liability on this income. Notably:
The income is exempt from the solidarity contribution under Article 43A of the Income Tax Code.
Any foreign tax paid on this pension income is not credited against the Greek tax due — a provision that has raised concerns about compatibility with EU double taxation principles and applicable Double Tax Treaties (DTCs).
Despite this, the explanatory report accompanying the legislation clarifies that DTCs remain fully applicable. In practical terms, public-sector pensions often remain taxable in the source country, whereas private pensions may become fully taxable in Greece, depending on the specific DTC provisions.
Greece’s Position in European Tax Planning
Greece is not alone in this approach. Countries such as Italy, Portugal, Malta, and Cyprus have introduced similar Non-Dom or foreign pension tax regimes. Greece’s offering stands out for its 7% flat rate, combined with quality of life factors such as climate, cost of living, and access to healthcare and residency permits.
As international mobility increases and retirees consider relocating within the EU, Greece's Non-Dom pension regime remains a compelling option for those seeking both tax efficiency and lifestyle benefits.
