With effect from 12 December 2019, a new non-dom regime is introduced, providing for an alternative way of taxing income derived abroad for individuals transferring their tax residence to Greece (non-dom), subject to the following conditions:
- taxpayers were not Greek tax residents for the previous seven of the eight years prior to the transfer of their tax residence to Greece, and
- it can be proved that they invest at least EUR 500,000 in real estate, businesses, or transferable securities or shares in legal entities based in Greece, either themselves or their relatives (i.e. spouses and those in the ascending or descending line), or through a legal entity in which they hold the majority of the shares.
Under this regime, individuals will pay a lump-sum tax of EUR 100,000 per tax year, irrespective of the amount of income earned abroad, for a maximum of 15 fiscal years. Moreover, it is possible to extend the regime to any of their relatives by paying an additional tax equal to EUR 20,000 per person per tax year. In such cases, the provisions of inheritance, gift, and parental grant tax will not apply.
It is noted that any tax paid abroad on income covered by the alternative taxation regime will not be offset against the tax liability of the above persons in Greece.
Furthermore, in case the persons who have opted for the non-dom regime earn taxable income that arises in Greece, this will be taxed in accordance with the general provisions of the ITC. In addition, in the event of non-payment of the full amount of the lump-sum tax, the special regime will be abolished, and these persons will be taxed for their worldwide income in accordance with the general provisions as of the tax year in question onwards.
It should be noted that taxpayers opting for the regime are not required to declare any income earned abroad. Furthermore, they will be able to justify the imputed income calculated based on deemed expenses and assets acquisition by importing funds from abroad.
The relevant application for the transfer of tax residence and for obtaining the non-dom status has to be submitted by individuals by 31 March of each tax year. Furthermore, it will be possible to apply for revocation of the non-dom status in any tax year during the 15-year period.