Financial motivation alone is never enough to decide upon one's return to a country or even to move to another employer. The excellent lifestyle, the mild climate along with the working conditions play a vital role in such decision making. Moreover, with the crisis now behind Greece and the long-term prospects in front of the country accompanied with political stability, will eventually result in an effective state and an economy that can offer more employment opportunities. Greece is one of the safest countries in the world for the expat and his family.
The non-dom regime for Employees and Individual Activity
Whilst it is widely known that brain drain is the worst threat to a country's prosperity, the Greek government voted very recently a new law to reverse this phenomenon and attract foreign investment from foreign or greek nationals who will opt to settle and work in Greece.
This legislation provides for as incentive an exemption from income tax and special solidarity contribution for 50% of the income gained in Greece for the next 7 fiscal years, either if a new job position is undertaken in a Greek company or a permanent establishment of a foreign company in Greece or if the interested individuals settle as self-employed.
Eligible to apply for this special non-dom regime are individuals who:
a) were not tax residents of Greece for the previous five (5) out of the six (6) years prior to the transfer of their tax residence to Greece;
b) transfer their tax residence from an EU member state or of the E.E.A. or by a state with which an administrative cooperation agreement in the field of taxation with Greece is in force,
c) provide services in Greece in the context of an employment relationship for a new job position or start business activities as self-employed; and
d) declare that they will remain in Greece for at least two years.
The non-dom regime for HNWIs
Law 4646/2019, in force as of 12.12.2019, introduced significant changes in the Greek Income Tax Code, among other, the long-anticipated non-dom regime for high net-worth individuals (HNWIs).
According to this new Law and the Ministerial Decision which further regulates in detail the implementation of the non-dom regime for high net-worth individuals (HNWIs) who now have worth-considering incentives for transferring their tax residency to Greece. The alternative tax regime (non-dom) dictates that the investor will pay a fixed tax of one hundred thousand (100,000) Euro per fiscal year, irrespective of the total income earned abroad. This favourable regime can apply for a maximum duration of 15 years. HNWIs who choose to transfer their tax residence to Greece will enjoy the privileges of special tax treatment provided the below conditions are met:
- The taxpayer has not been a tax resident of Greece for the past seven (7) out of (8) eight years prior to the transfer of his/her tax residence to Greece and
- The taxpayer has to prove that either (s)he or a relative have invested at least five hundred thousand (500,000) euro in real estate or business or transferable securities or shares in legal entities seated in Greece; the investment may have been made through a legal entity in which the taxpayer holds the majority of the shares.
Moreover, the individual has the right to request the extension of this regime to a family member. In that case, they will pay an additional tax of 20,000€ per relative while provisions on gifts, inheritance and parental gifts do not apply.
With the payment of this fixed tax, the individual bears no further tax obligation for income earned abroad and (s)he is also exempt from inheritance or gift tax on properties located abroad.
The non-dom regime for Foreign Pensioners
Following the above- mentioned introduction of the non-dom regime for high net-worth individuals in Greece, the Greek Parliament voted further the Law 4714/31.7.2020 regulating the non-dom regime specifically for foreign pensioners.
In brief this law stipulates that individuals, being beneficiaries of pension income arising from abroad and wishing to transfer their tax residency to Greece, are subject to an alternative method of taxation for the income that arises abroad, if cumulatively:
a) they were not tax residents of Greece in the previous five (5) out of the six (6) years prior the transfer of their tax residency to Greece, and
b) they transfer their tax residency from a state, which has in force an agreement on administrative cooperation in the field of taxation with Greece.
If the taxpayer is accepted to be included in the alternative way of taxation for income arising abroad, then the individual shall pay, once-off, a tax at a rate of seven percent (7%) on the total of his income obtained abroad, each year.
With the payment of this tax in Greece, every tax liability of the individual for this income arising abroad is considered to be paid in full.
The Greek Golden Visa
Further to the above, the Greek Golden Visa program continues to be a constant force in attracting foreign capital outside the EU. With a minimum amount of €250,000 in property investment, the programme ranks first among European countries and offers a permanent residence permit to the investors, as long as they own the property.
The additional advantages of the programme include the possibility of non-compulsory presence of the investor in the country, visa free travel throughout the Schengen Countries, the renting out of the property, the extension of the residence permit to the members of his family and entitlement to apply for Greek Passport after seven years of residence.
In fact, British investors are expected to be added to this list from 2021, as they have high purchasing power and have strong ties with Greece due to tourism.
Further incentives for the construction/property sector in Greece
The government's measures to stimulate the Greek construction sector are as follows:
Suspension of VAT: new built properties (with building permits as from 2006) may be exempt from 24% VAT and buyers will have to pay only 3% transfer tax, as is currently the case for old properties.
In fact, construction can be the second source of economic growth after tourism. The imposition of 24% VAT on new real estate transactions acted as a disincentive to investment in new houses. This measure is expected to boost the economy in the construction sector and the demand for new built properties.
Tax-free donations for the purchase of a house: Zero tax on cash donations of up to 150,000 euros from parents to their children for first home purchase and tiered rates from 1% to 10% for larger amounts provided for by law. Until now, financial donations from parents to their children were taxed at a rate of 10%.
"Freezing" of capital gains tax: Capital gains tax on transfers of immovable property imposed on the seller of a property has been suspended for three years, namely until 31 December 2022.
Tax deduction for renovations of real estate: Significant funds are also expected to be channeled towards renovations/reconstructions of existing properties, which is considered an even greater scope for individuals, since the vast majority of interested parties do not have the purchasing power to purchase housing, but are interested in upgrading their existing property. In this context, the regulation on the provision of a 40% tax credit on service costs for the energy, functional and aesthetic upgrading of buildings is of particular importance.
For further information please contact Maria Sarantopoulou at maria.sarantopoulou@eurofast.eu
Eurofast is a regional business advisory organisation employing local advisors in over 23 cities in South East Europe & Middle East (SEEME). The Organisation is uniquely positioned as one stop shop for investors and companies looking for professional services in South East Europe & Middle East.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
