Quick answer: Article 5A lets a new Greek tax resident pay a flat €100,000 a year on all foreign income for up to 15 years, with no duty to declare or remit it, in exchange for a €500,000 Greek investment. A Golden Visa property at €500,000 or more satisfies the investment test by itself.
Greece runs one of the most aggressive flat-tax offers in Europe and almost none of the property content written for foreign buyers mentions it. Article 5A of the Income Tax Code, in force since Law 4646/2019 and untouched by the 2026 reform, converts a wealthy newcomer’s entire foreign income into one fixed annual payment of €100,000, and the €500,000 investment that opens the door can be the same deed that carries a Golden Visa.
This guide covers the regime as it stands on 22 August 2026: the two entry tests, what the flat tax does and does not cover, the application mechanics and deadlines, the family arithmetic over 15 years, and the failure modes that end the status early, with the combined Golden Visa play treated in its own companion guide.
What Is the Article 5A Non-Dom Regime?
Article 5A is an alternative taxation election: a person who transfers tax residence to Greece pays a fixed €100,000 each tax year on all foreign-source income, for a maximum of 15 years, instead of the progressive scale that otherwise reaches 44%. The election is made once, granted by decision of the tax authority, and renews by payment.
What the election changes, in one view:
| Question | Ordinary Greek resident | 5A non-dom resident |
|---|---|---|
| Foreign dividends, interest, gains | Progressive scale / 15% by class | Covered by the flat €100,000 |
| Duty to declare foreign income | Yes, fully | No declaration required |
| Remittance rules | Not applicable | None, bring funds in freely |
| Foreign inheritance and gifts | Greek inheritance tax rules | Exempt while regime holds |
| Greek-source income | Ordinary rules | Ordinary rules, unchanged |
| Duration | Indefinite | 15 tax years maximum |
Greece’s offer sits at half the price of its only serious European rival and arrived at exactly the right moment. Italy’s equivalent lump-sum regime has charged €200,000 a year since its 2024 doubling, against Greece’s €100,000, for a comparable 15-year term and a comparable foreign-income shield. The UK then abolished its resident non-dom regime outright in April 2025, releasing tens of thousands of internationally mobile taxpayers who had priced their lives around exactly this kind of arrangement. Greece is one of three realistic landing places for that audience, alongside Italy at twice the price and the UAE outside Europe altogether, and the post-2025 inflow of former UK non-doms into Athens Riviera and Kolonaki stock is a visible part of the demand behind prime pricing. For a buyer weighing jurisdictions, the arithmetic is stark: 15 years of Italy costs €3 million for a principal; 15 years of Greece costs €1.5 million.
Who Qualifies for the €100,000 Flat Tax?
Eligibility requires passing two tests together: a residence history test, no Greek tax residence in 7 of the 8 years before the move, and an investment test of at least €500,000 into Greek assets, completed within 3 years of the application. Both are documentary tests; there is no wealth minimum and no nationality restriction.
- The 7-of-8 test. Returning Greeks qualify if they have genuinely been abroad long enough; a person who spent, say, 2019 to 2025 as a UK or Gulf resident passes comfortably.
- The €500,000 test. Qualifying categories are Greek real estate, securities of Greek issuers, and equity in Greek companies, alone or combined. The money must sit in a Greek bank account before the application is filed, even though completion of the investment may take up to 3 years.
- The exemption from the test. An applicant who already holds a residence permit through the Golden Visa investment categories is treated as satisfying the investment condition, provided the underlying investment is at least €500,000 and maintained.
- Family extension. A spouse, children and parents can join by extension at €20,000 a year each, with no investment of their own.
The residence transfer itself follows the ordinary rules: once Greece is your centre of vital interests or you exceed 183 days, you are resident, and the 183-day mechanics apply as they would to anyone.
Which Investments Satisfy the €500,000 Requirement?
Greek real estate, Greek-issuer securities and Greek company equity all qualify, alone or in combination, and a property already bought for a Golden Visa counts if it reaches €500,000. The practical routing for this site’s readers is therefore a property question: which deed you buy determines whether one asset carries both files.
| Route | Satisfies 5A alone? | Note |
|---|---|---|
| €800,000 Attica / prime-tier Golden Visa deed | Yes | One asset, both files |
| €500,000+ regional property | Yes | Above the €400,000 GV floor anyway |
| €400,000 regional Golden Visa deed | No, €100,000 short | Top up with securities or a second unit |
| €250,000 conversion-route project | No | Needs €250,000 more in qualifying assets |
| Greek listed shares or bonds, €500,000 | Yes | No property required at all |
Three execution points matter. The funds must arrive in a Greek account in the applicant’s name before the application, which puts the Circular 1/2026 banking trail on the critical path twice. The investment must then be maintained: a sale without replacement inside 6 months revokes the status. And the 3-year completion window runs from the application date, so an off-plan purchase with a 2029 delivery can still anchor a 2026 election.
Structuring a €500K+ purchase to carry both the Golden Visa and the 5A election? We shortlist deeds that clear the 120 m² rule and the investment test in one title.
What Does the Flat Tax Cover, and What Stays Outside It?
The €100,000 settles Greek tax on every category of foreign-source income, dividends, interest, capital gains, rents, royalties, pensions, with no obligation to declare the amounts and no tax on bringing the money into Greece. Outside it sit all Greek-source income and, importantly, the running taxes on Greek property itself.
Still payable by a 5A resident:
- Greek rental income at the ordinary 15/25/35/45% scale on gross rent, per the non-resident rental guide, which applies to residents identically.
- ENFIA on Greek property at €2.00 to €16.20 per square metre, plus the wealth supplement above roughly €500,000 of objective value.
- FMA transfer tax at 3.09% on any further Greek purchases.
- Greek-source salary or business profit under the ordinary 9% to 44% scale.
The estate-planning clause is the quietly decisive one, and it is worth stating precisely. While the regime holds, assets situated outside Greece pass by inheritance or gift entirely outside Greek inheritance and gift tax: a €10 million foreign portfolio passing to two children during the regime attracts zero Greek charge, where ordinary Greek residence would expose the same transfer to the standard Category I scale after allowances. Over a 15-year horizon that single exemption is frequently worth more than the income shelter itself, and it is the reason estate lawyers, not income tax advisers, drive many 5A elections. Greek-situs assets, including the qualifying property, stay inside the ordinary rules in the inheritance tax guide, so the planning line is drawn by where each asset sits, not by who owns it.
How Do You Apply, and by When?
The application goes to AADE by 31 March of the year the regime is to begin, accompanied by proof that the €500,000 has reached a Greek account; supporting documents may follow within 60 days, the authority decides within the year, and the first €100,000 is due in one instalment by the last working day of July.
The working timeline for a 2027 start:
- 2026: open the Greek bank account, wire the funds, complete or contract the qualifying investment.
- By 31 March 2027: file the 5A election with AADE, bank certificate attached.
- Within 60 days: lodge any remaining documents, residence history evidence included.
- On approval: pay €100,000, plus €20,000 per included family member, by end of July 2027.
- Each later year: pay by July; the regime renews without re-application until year 15.
Missing the July payment ends the regime for good, not just for the year, and the 31 March deadline is hard: file 1 April and the earliest start slips a full tax year. Applicants coming from treaty states should also clear exit-tax and tie-breaker questions at home before the move; Greece maintains 57 double tax treaties, and the treaty mechanics for property income differ by country.
What Does 5A Cost a Family Over 15 Years, and When Does It Win?
The regime beats the ordinary scale once foreign income clears roughly €230,000 a year for a single applicant, and the full 15-year cost for a family of four inside the regime is €2.4 million against unlimited ordinary-scale exposure. Below the break-even, the ordinary scale, newly cut by Law 5246/2025, is simply cheaper.
| Profile | Annual foreign income | Ordinary scale (approx.) | 5A flat cost | 5A saves |
|---|---|---|---|---|
| Single, modest | €150,000 | €61,000 | €100,000 | No |
| Single, break-even | €230,000 | €96,000 | €100,000 | About even |
| Single, HNW | €500,000 | €215,000 | €100,000 | €115,000/yr |
| Couple, HNW | €1,000,000 | €435,000 | €120,000 | €315,000/yr |
| Family of four, UHNW | €3,000,000 | €1,315,000 | €160,000 | €1,155,000/yr |
Ordinary-scale figures approximate the 2026 brackets applied to investment income mixes; dividends and gains taxed at class rates can sit below the top band, so run your own composition. The harder-to-price benefits sit outside the table: no foreign income disclosure to Greek authorities, no remittance planning, and the inheritance exemption, which on a €10 million foreign estate passing to children can exceed every year of flat tax combined.
What Are the Advantages and Disadvantages of Electing 5A?
The advantages are certainty, privacy and scale: one number a year, no foreign disclosure, 15 years of it. The disadvantages are the floor and the edges: €100,000 is a floor you pay in loss years too, Greek-source income gains nothing, and the status depends on an investment you must not sell uncovered.
Advantages
- Flat €100,000 whatever the income: at €3 million of foreign income the effective rate is 3.3%.
- No declaration of foreign income and no remittance restrictions.
- Foreign assets outside Greek inheritance and gift tax for the regime’s life.
- Half the price of Italy’s €200,000 equivalent, in the same currency and time zone.
- Family joins at €20,000 each without further investment.
Disadvantages
- €100,000 is due even in a year the portfolio loses money.
- Nothing changes on Greek income: rent from your own Athens flat still taxed at up to 45%.
- Status is welded to the €500,000 investment; a 6-month gap after a sale revokes it.
- 15-year ceiling, then the full ordinary scale returns.
- Becoming Greek-resident can trigger exit taxes in the country you leave; the treaty side needs advice before, not after.
What Are the Risks and Red Flags Before Electing?
The regime’s failure modes are administrative, and all four are avoidable: filing after 31 March, letting the qualifying investment lapse, missing the July payment, and electing below the income break-even where the flat tax is simply a worse deal. A fifth risk sits abroad, in the exit rules of the country being left.
- Deadline risk. 31 March is not extendable; a late file costs a year of the regime.
- Investment continuity. Selling the qualifying asset and re-buying 7 months later ends the status retroactively for the gap year. Replace within 6 months, documented.
- Payment default. One missed July instalment terminates the regime permanently.
- Break-even error. At €150,000 of foreign income the ordinary 2026 scale costs about €61,000; electing 5A there donates €39,000 a year to the Greek state.
- Departure-country exposure. Exit taxes, trailing residence rules and treaty tie-breakers vary; UK leavers face temporary non-residence rules, US citizens remain taxed by citizenship and gain little from 5A at all.
Which Buyer Scenario Fits the 5A Election?
The regime is built for three profiles: the former UK non-dom repricing after April 2025, the Gulf-based family formalising a European base, and the entrepreneur exiting to a passive portfolio. For each, the deciding variables are foreign income above €230,000 and willingness to actually live in Greece.
- Above €230,000 of foreign income: elect, the flat tax wins.
- Below it: take the ordinary 2026 scale and skip 5A.
- Estate-heavy, income-light: elect for the inheritance shield alone.
The displaced UK non-dom. Foreign portfolio income of €800,000 a year meets a UK regime that no longer exists. Greece at €100,000 flat, with an €800,000 Riviera deed carrying both the Golden Visa and the 5A investment test, prices the whole move at under half the Italian alternative.
The Gulf-based family. Income already untaxed at source; the draw is the inheritance shield and a documented EU residence. 5A adds certainty at €160,000 a year for four people, and the Greek property throws off ordinarily-taxed rent that the family can leave to compound.
The exited founder. A €15 million portfolio yielding €600,000 abroad: 5A caps Greek tax at €100,000, saves roughly €155,000 a year against the scale, and leaves the founder free to spend Greek summers without counting days against a tax cliff.
Next steps: the combined Golden Visa and non-dom strategy · the 2026 tax reform in full · the Golden Visa hub.
Frequently Asked Questions
Article 5A of the Greek Income Tax Code, introduced by Law 4646/2019, lets a person who moves tax residence to Greece pay a flat €100,000 a year on all foreign-source income instead of the progressive scale, for up to 15 years. Foreign income need not be declared or remitted, and foreign assets are exempt from Greek inheritance and gift tax while the regime holds. Greek-source income remains taxed normally.
Two tests. First, you must not have been a Greek tax resident in 7 of the 8 years before the move. Second, you must invest at least €500,000 in Greek real estate, securities or business equity, completed within 3 years of applying; the funds must reach a Greek account before the application. Holders of a Golden Visa investment at or above €500,000 meet the investment test with the same asset.
Yes, Greek real estate is a qualifying 5A investment category, so an €800,000 Attica Golden Visa deed satisfies the test outright. A €400,000 regional deed does not on its own: it must be topped up to €500,000 with further qualifying investment, for example additional property or listed Greek securities. The two applications remain separate files with separate authorities.
€100,000 a year for the principal, plus €20,000 a year for each family member brought into the regime, paid in one instalment by the last working day of July. A couple with two adult children inside the regime pays €160,000 a year flat, whatever their worldwide income. Family members join by extension of the principal's status, not by their own investment.
By 31 March of the tax year the regime is to start, with the Greek tax office (AADE). Proof that the €500,000 has been transferred to a Greek account must accompany the application, and remaining documents may follow within 60 days. AADE decides within the year; the flat tax for that first year is then due by the end of July.
No. The flat tax covers foreign-source income only. Greek rental income, a Greek salary or Greek business profits are taxed under the ordinary rules, including the 15% to 45% rental scale on gross rent. A 5A resident letting their Greek property pays rental tax on it exactly as any other owner does.
Yes, in two ways. It lapses automatically if the qualifying €500,000 investment is sold and not replaced, with a gap of more than 6 months revoking the status, and it ends if the annual flat tax is not paid in full by the July deadline. It also simply expires after 15 tax years with no renewal, after which the ordinary progressive scale applies.
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