For taxpayers who wish to invest in Greece
This provision was the first to be implemented and is analyzed in Article 5A/ Law 4172/2013, as it applies from 12/12/2019 and is analyzed in Circular A.1036/2020.
According to this, the taxpayer, a natural person, who was not a tax resident of Greece in the previous seven out of eight years before the transfer of his tax residence to Greece and proves that they or their relative invest an investment amount of more than 500,000 euros, will pay a flat-rate lump sum tax of 100,000 euros for the global income generated abroad. Also, the natural person has the possibility to request the extension of the application of this article to a relative, in which case an amount of tax equal to 20,000 euros will be paid for each relative, without the provisions of taxation of gifts, inheritances and parental benefits being applied.
Such investment may be made within three years from the date of application and may be made directly by the natural person or through a legal person or legal entity in which respectively it holds a majority of the shares or units in immovable property or in business or in transferable securities or in shares or units in legal persons or legal entities based in Greece.
The tax in this article shall be paid each tax year in one instalment until the last working day of July and shall not be offset against other tax liabilities or any credit balances of the persons who have been subject to the alternative method of taxation. Any tax paid by these same persons abroad on the income covered by the alternative way of taxation is not offset against any tax liability in Greece. For the late payment of this tax, the provisions of Law 4174/2013 as in force apply.
Finally, in the event that the natural person does not pay the entire tax, by December 31st of the year in question, they cease to be subject to the provisions of said article and from the tax year concerned onwards they are taxed for their global income under the general provisions of Law 4172/2013.