In June 2026 Greece quietly rewrote the procedure behind its non-dom tax regime — the €100,000-a-year flat tax under Article 5A of the Income Tax Code, and the 7% regime for foreign pensioners under Article 5B. The change that matters most is a deletion: the long-standing 31 March filing deadline is gone from the statute.
The substance of both regimes is untouched. What moved is the calendar, and the calendar is what most advisers were still quoting from memory. Here is what actually applies for the 2026 tax year, and where the traps are.
What changed: Law 5313/2026, Article 94
Article 94 of Law 5313/2026 (Government Gazette A’ 102, published 25 June 2026) amended Articles 5A and 5B of the Income Tax Code. Four changes:
- 1. The statutory 31 March application deadline was removed and delegated to a decision of the Governor of the Independent Authority for Public Revenue (AADE).
- 2. The statutory review deadlines were removed — previously the administration had to decide a 5A application by the end of June, and a 5B application within 60 days.
- 3. Payment moved from July to December. The €100,000 lump sum (plus €20,000 per family member admitted) and the 7% pension tax are now paid in one instalment by the last working day of December.
- 4. Technical references were updated to the new Tax Procedure Code (Law 5104/2024).
Neither the eligibility tests nor the benefits changed. Anyone describing the 2026 reform as “loosening” the qualifying conditions is reading a different law.
The new calendar: AADE Decision A.1147/2026
The operational rules now come from Decision A.1147/2026, issued by the AADE Governor and in force from 20 July 2026. For Article 5A:
- File by 30 September of the year of arrival, for the regime to apply from that year; or by 30 September of the following year, for it to apply from the year after arrival.
- The 2 July pivot. A taxpayer who transfers tax residence up to 2 July of a given year may choose either the year of arrival or the following year as the first year of inclusion. After 2 July, the application can only take effect from the following year. For anyone relocating in the second half of the year, this converts a moving date into a tax decision.
- Supporting documents may be filed up to 31 October of the tax year for which inclusion is requested.
- The administration decides by the last working day of November.
- The tax is payable by the last working day of December, in one instalment. On full payment, all tax obligations on foreign-source income are exhausted — and per the decision, foreign-source income subject to the alternative taxation carries no filing obligation.
- Applications and documentation may be submitted digitally, by post or in person, to KEFODE Attica, Department A8′ (or KEFODE Thessaloniki, Department A5′).
- Family members — spouse, parents, children — can be added either with the initial application or at any later point.
The transitional reach is broader than it looks: the rules apply to applications submitted after 25 June 2026, to applications still pending on that date, and to 2026 assessment acts where the tax was still due when the decision entered into force.
Who qualifies under Article 5A
Cumulatively:
- The individual must not have been a Greek tax resident for seven of the eight years preceding the transfer;
- A qualifying investment of at least €500,000 in Greek real estate, businesses, transferable securities, or shares/units in Greek entities, to be completed within three years of applying. The investment may be made by the taxpayer, by a relative, or through an entity in which the taxpayer holds the majority.
Once admitted, the taxpayer pays €100,000 per tax year on all foreign-source income, regardless of amount, for up to 15 tax years. Each additional family member admitted adds €20,000 per year, and the admission of relatives brings exemption from inheritance, gift and parental-grant tax on that basis.
Two features deserve more attention than they usually get:
The investment requirement is waived for Golden Visa holders.AADE’s own published guidance states that the second condition does not have to be met where the individual “has acquired and retains” a residence permit for investment activity in Greece — under Article 16 of Law 4251/2014 in the AADE text, the provision that began the Greek Golden Visa programme and has since been consolidated into the Migration Code (Law 5038/2023). Qualifying investments must have been made from 12 December 2019 onwards; eligible categories and retention periods are set by Ministerial Decision 46834/2023 (Gazette B’ 3393/19.05.2023, as amended). In practice this means a family that already holds Greek property through the Golden Visa route can access the €100,000 flat tax without committing a further €500,000.
Foreign movable property is outside the Greek inheritance and gift tax net. Article 5A exempts foreign-situated movable property on death, gift and parental grant, whether the taxpayer acquires or transfers it — and irrespective of the beneficiary’s own tax residence. For families planning succession, that is often worth more than the headline rate.
Article 5B: 7% for foreign pensioners
Article 5B is the lighter-touch regime, and its conditions are unchanged: the individual must not have been a Greek tax resident for five of the previous six years, must receive a pension arising abroad, and the transfer must come from a state with which Greece has an administrative cooperation agreement in tax matters. No investment is required. The rate is a flat 7% on total foreign-source income — not a marginal rate — for up to 15 tax years, and the payment date has likewise moved to December.
One planning point that predates the reform and survives it: the 7% rate is decisive when pension income dominates. Where a family’s foreign income is mostly portfolio income, the arithmetic has to be run before choosing between 5A and 5B.
Where the regimes actually pay off
Using the 2026 personal income tax scale (Law 5246/2025: 9% up to €10,000, 20% to €20,000, 26% to €30,000, 34% to €40,000, 39% to €60,000, 44% above, with a basic credit of roughly €777), and comparing only the burden on foreign-source income:
| Annual foreign-source income | Rational choice |
| Below roughly €28,000 | Neither regime; the ordinary scale is lighter |
| €28,000–€250,000 | The 7% regime is clearly better |
| Above €250,000 | Article 5A starts to beat the ordinary scale |
| Above roughly €1.43m | Article 5A’s €100,000 cap beats 7% with no ceiling |
Put differently: a family with €300,000 of foreign income pays €21,000 under the 7% regime but €100,000 under Article 5A. A family with €1.5m of foreign income pays €105,000 under 7%, with narrower scope, but €100,000 under Article 5A. The regimes are not interchangeable, and the crossover is arithmetic, not marketing.
Three traps
1. Residence permits are not tax regimes. Most Greek residence routes — the Golden Visa, the financially independent person (FIP) permit, the digital nomad visa — are immigration instruments. The FIP permit requires no investment but demands over 183 days of physical presence a year, which makes the holder a Greek tax resident taxed on worldwide income at progressive rates. It does not carry the Article 5A waiver, which is reserved for the investment-activity permit. Clients often arrive believing the permit solved the tax question.
2. Golden Visa holders waste the waiver. Any family already holding a Greek investment-activity permit should run two tests: the seven-of-eight-years non-residence test, and the amount of foreign-source income. Where both pass, Article 5A is essentially a procedural step rather than a fresh capital commitment. This is rarely raised at renewal.
3. Day-count evidence. Greece applies the 183-day test to any rolling 12-month period (Article 4 of the Income Tax Code), not to the calendar year — wider than the “calendar year” formulation circulating online, but also harder to reconstruct after the fact. Entry and exit records, lease agreements, utilities, medical records and school enrolments need to be preserved from the first day of relocation. Once two states simultaneously claim residence, the cost of resolving it exceeds the cost of the original application. The interaction between residence, domicile and the source of economic interests is set out in our analysis of tax residence after Announcement No. 21.
Procedural risk after the reform
Removing the administration’s review deadlines is a double-edged change. A 60-day statutory answer period used to give applicants a planning anchor; now there is none. Applicants should file early and build a margin into the timeline rather than treating submission as admission.
Rejections at the KEFODE level are not the end of the road. In decision Π32/2026, the Piraeus Administrative Court of First Instance annulled a KEFODE Attica rejection concerning a tax-residence transfer, holding that the administration had conflated the acquisition of a corporate office with the actual start of the employment relationship. The dispute concerned Article 5C rather than 5A or 5B, but the procedural lesson transfers: the competent office is KEFODE Attica, and its refusals are reviewable before the administrative courts.
The regional comparison, briefly
Greece’s €100,000 regime looks different in 2026 than it did in 2024. Italy raised its flat tax for new arrivals to €300,000 a year, and the United Kingdom abolished its non-dom regime in April 2025. For families that were weighing London or Milan, Greece is now the only EU jurisdiction in the €100,000 band. Other EU regimes have their own constraints, and so do non-EU alternatives — see our note on Turkey’s 20-year foreign income exemption. For the property-tax side of a Greek relocation, the recent change to the transfer tax for non-EU buyers matters as well. The relevant comparison for a specific family is a separate exercise, which is why we run the analysis jurisdiction by jurisdiction rather than selling one programme.
Practical sequencing
The order cannot be reversed: first model the income composition and the day count, then choose the residence and tax-residence combination. Three starting points:
- Already holding Greek property? Run the seven-of-eight test and the foreign-income tests against Article 5A.
- Still choosing a jurisdiction? Put Greece, Cyprus and the UAE on one page and compare the same numbers across all three.
- Already in Greece? Fix the applicable filing window and the first year of inclusion, then assemble the day-count evidence.
About GlobalPropAI (信达海外): we are an independent advisory practice for cross-border families, working alongside a Big Four China tax partner and a US CPA. We do not sell immigration products or investment programmes; we design and test the structure. For a review of your own position, write to globalpropai2@gmail.com.
*This article is a summary of published legislation and administrative guidance as at 20 September 2026. It is not legal or tax advice.*
FAQ
1. Is the 31 March deadline for the Greek non-dom regime gone?
Yes. Article 94 of Law 5313/2026 removed the statutory 31 March filing deadline and delegated it to an AADE Governor decision. Decision A.1147/2026 sets 30 September of the year of arrival — or of the following year — as the filing date.
2. When is the €100,000 flat tax paid now?
By the last working day of December, in one instalment. It used to be due by the last working day of July.
3. Do I still need to invest €500,000 to use Article 5A?
Not if you already hold and retain a Greek investment-activity residence permit (the Golden Visa route). AADE’s published guidance waives the investment condition in that case. Otherwise, a qualifying investment of at least €500,000 must be completed within three years.
4. Does the 7% pension regime still apply?
Yes. Article 5B was not substantively changed: 7% flat on foreign-source income, for taxpayers who were non-resident for five of the previous six years, where the pension arises in a state with an administrative cooperation agreement with Greece.
5. Does a Greek residence permit make me a Greek tax resident?
No. Tax residence follows the 183-day test measured over any rolling 12-month period, or the centre of vital interests. A residence permit is an immigration status; the tax position is a separate election.