The non-dom landscape has shifted sharply across Europe. Here is where Greece now stands — and how it compares.
A Reshaped European Landscape
The European tax landscape for high-net-worth individuals has changed dramatically in a short span. The United Kingdom abolished its centuries-old remittance-based non-dom regime in April 2025, replacing it with a far more limited Foreign Income and Gains system. Italy has tripled the price of its flat-tax regime. Portugal has narrowed its successor program to qualified professionals and removed its pension benefits. As these doors close or grow more expensive, internationally mobile wealth is actively seeking stable, predictable jurisdictions.
In 2026, Greece’s alternative-taxation framework — the “non-dom” regime under Article 5A of the Greek Income Tax Code — stands out not as the cheapest or the most aggressive option, but as one of the most balanced: a fixed, predictable cost, a long horizon, and a clear pairing with a residency program that requires no physical presence. Here is how it works, and how it compares.
The Greek Non-Dom Regime (Article 5A)
Greece’s Article 5A of Law 4172/2013 regime offers a high degree of tax predictability. A qualifying individual who transfers their tax residency to Greece pays a fixed annual lump-sum tax of €100,000, which covers their entire liability on all foreign-sourced income — regardless of the amount earned abroad. The core features:
- The flat tax: €100,000 per year on all foreign-source income, in place of progressive rates that otherwise reach up to 44%.
- Family inclusion: family members can be added to the regime for an additional €20,000 per person, per year.
- Duration: the benefit applies for up to 15 years.
- Investment requirement: a minimum €500,000 investment in Greek real estate, businesses, or securities within three years — waived if the applicant already holds a Greek residence permit obtained through investment.
- Eligibility: the applicant must not have been a Greek tax resident for at least seven of the eight years preceding the transfer.
- Reporting: there is no obligation to declare foreign-source income in Greece. (Greek-source income remains taxable under ordinary rules, and the lawful origin of funds may still be examined in an audit.)
Inheritance and gift tax — the accurate position
This point is often overstated, so it is worth being precise. The non-dom regime does not, by itself, provide a blanket exemption from Greek inheritance and gift tax. However, where family members are included in the regime, the provisions on inheritance, gift, and parental-grant tax do not apply to assets located abroad transferred between them. This is a meaningful but specific benefit tied to family inclusion—not an automatic, universal shield for a global estate. Anyone planning around estate and succession should obtain tailored advice on their particular structure.1
How Greece Compares Across Europe in 2026
As Greece has held its position, competitor regimes have either become significantly more expensive or closed to passive wealth. The contrasts below are current as of 2026.
Italy: now €300,000 per year
Italy’s lump-sum regime was once Greece’s closest rival, but the 2026 Budget Law raised the annual flat tax for new residents from €200,000 to €300,000, with the charge for each family member doubling to €50,000. A family of four relocating to Italy in 2026 would therefore face roughly €450,000 in annual costs. (Existing beneficiaries are grandfathered at the rate in force when they arrived.) Italy also levies separate annual wealth taxes on foreign financial assets and foreign real estate that the flat tax does not replace. This repositions Italy firmly at the top end of the market — compelling for very large foreign incomes, but considerably more expensive than Greece’s €100,000 for most families.
Cyprus & Malta: remittance and SDC models
Cyprus exempts non-domiciled residents from its Special Defense Contribution, giving 0% tax on foreign dividends and interest for the first 17 years of tax residency, and requires as little as 60 days of physical presence per year. Under the 2026 Cyprus tax reform, once that initial 17-year window ends, a non-dom whose domicile of origin is outside Cyprus may extend the exemption for up to two further five-year periods by paying a €250,000 lump sum per period — a potential maximum of 27 years. Malta offers an indefinite remittance-basis regime under which offshore foreign income remains untaxed unless remitted. Both are excellent for passive dividend earners, but Greece’s lump-sum settlement of foreign-income liability in a single, predictable payment avoids remittance tracking.
Spain: the Beckham regime and a contested ruling
Spain’s “Beckham” regime taxes Spanish-source employment income at a flat 24% (up to €600,000) for six years and broadly exempts foreign passive income, shielding foreign assets from Spain’s wealth tax. One recent development adds a wrinkle: in Resolution 3697/2025 (17 July 2025), Spain’s Central Economic-Administrative Tribunal (TEAC) established a binding administrative criterion that Beckham beneficiaries must impute deemed rental income on their Spanish primary residence (1.1%–2% of cadastral value) — unlike ordinary residents, whose main home is exempt. Importantly, this is contested: the High Court of Justice of Madrid reached the opposite conclusion (judgment 665/2025), and the question is expected to reach the Supreme Court. For now, it represents uncertainty rather than a settled cost, but it is a live issue prospective movers should weigh.
Portugal: a pivot away from passive wealth
Portugal’s widely used Non-Habitual Resident program has been replaced by the IFICI regime (often called “NHR 2.0”). This is no longer a general wealth or retiree haven: it targets highly qualified professionals, researchers, and certified startup founders, and requires a qualifying professional activity maintained each year. Crucially for retirees, foreign pension income — which the old NHR taxed at a reduced rate — is now fully taxable under IFICI. For passive or retirement-oriented wealth, Portugal is materially less attractive than it was.
At a glance
| Jurisdiction | Headline cost | Position in 2026 |
|---|---|---|
| Greece (Art. 5A) | €100,000/yr (+€20,000 per family member) | Up to 15 years; €500,000 investment; no minimum stay to keep residency. |
| Italy | €300,000/yr (+€50,000 each) | Tripled for 2026 arrivals; separate foreign-asset wealth taxes apply. |
| Cyprus | 0% SDC; €250,000 per 5-yr extension after year 17 | 17 years, extendable to 27; 60-day residency option. |
| Spain (Beckham) | 24% on Spanish income to €600k | 6 years; foreign passive income broadly exempt; primary-residence imputed-income point contested. |
| Portugal (IFICI) | 20% on qualifying Portuguese income | 10 years; professionals only; foreign pensions now fully taxable. |
| United Kingdom | n/a | Non-dom regime abolished April 2025; replaced by limited 4-year FIG system. |
The Golden Visa Synergy — and a New Era of Transparency
For non-EU citizens, Greece offers something most competitors do not: the tax regime pairs naturally with the Greek Golden Visa, a residency program that requires no minimum physical presence to maintain. An investor can hold permanent EU residency, access the Article 5A regime, and continue to live and work primarily elsewhere — a genuine “Plan B” held remotely. (Investors should note the two are separate legal frameworks with separate conditions; the €500,000 non-dom investment threshold and the Golden Visa’s real-estate thresholds are not the same figure.)
Greece has also moved to protect the integrity of this pathway. In April 2026, the Ministry of Migration issued Circular No. 1/2026, which standardized the application of the Golden Visa rules nationwide and explicitly targeted misleading representations and “cash-back” arrangements that artificially lower the actual investment amount, with a referral to the tax and anti-money-laundering authorities. Far from a deterrent, this transparency drive is a feature: it removes ambiguity and ensures the program functions as a credible, premium pathway rather than a loophole.
A Word on Substance and Source of Funds
The clear direction across Europe — and specifically in Greece — is toward greater scrutiny and genuine substance. Anyone considering relocation should prepare accordingly:
- Document the lawful source of invested funds thoroughly — bank statements, sale contracts, and corporate distributions — well before filing.
- Map the tax-residency transition carefully across both the origin and destination jurisdictions, including the timing of when foreign-source income falls in or out of each net.
- Treat the residency permit and the tax regime as distinct steps with distinct conditions, and align filings across jurisdictions to avoid mismatches in the transition year.
Handled properly, these are routine. Handled carelessly, they are where problems arise — which is precisely why expert, compliant guidance matters more in 2026 than it did even a year ago.
The Verdict
As the UK closes its doors and Italy prices out all but the ultra-wealthy, Greece has combined a moderate, predictable cost with a long horizon, generous family inclusion, and a residency program that asks nothing of your physical presence. It is not the cheapest option in every scenario, nor the right answer for every profile — but for internationally mobile families seeking stability, predictability, and a credible European base, Greece’s Article 5A regime is among the most balanced and strategic choices in Europe today
Andenhouse Advisors guides clients across the Americas through both the Greek Golden Visa and the tax-residency questions that accompany it — honestly, and with full attention to the 2026 compliance environment.
Reference
- Greece amended several of these provisions through Law 5222/2025 (enacted July 2025), which broadened family-office and family-member rules. Investors evaluating the most recent changes — including the precise conditions for adding family members — should confirm the current details with a qualified Greek tax adviser, as implementation continues to develop. ↩︎
Disclaimer:
This article is provided for general information only and does not constitute legal, tax, immigration, or financial advice. Tax regimes in Greece and other jurisdictions change frequently and their application depends on individual circumstances; the figures and rules described — including those of other countries — should be confirmed against current official sources or a qualified professional in the relevant jurisdiction before acting. Andenhouse Advisors does not provide tax advice and does not guarantee any specific tax outcome.
