Article 5C` A 1087/15.04.2021  

This measure is included in a bill that is to be passed, so what we will mention will apply, barring unforeseen circumstances. According to the draft law, therefore, there will be a special way of taxing income from salaried employment and business activity generated in Greece by natural persons transferring  their tax residence to Greece.  

The basic prerequisites are for the applicant to:  

• Not be a resident for tax purposes in Greece for the previous seven out of eight years, before transferring his tax residence to Greece
• Transfer their tax residence from an EU or EEA Member State or from a state, with which an agreement on administrative cooperation in the field of  taxation with Greece is in force
• Provide services in Greece in the context of work relations within the meaning of par. 2 of article 12 of Law 4172/2013, which is exercised either in a  domestic legal person or legal entity, or in a permanent establishment of a foreign company in Greece  
• Declares that they will remain in Greece for at least two years. 

The tax incentive given is that, if the taxpayer's application is accepted, the natural person is exempted from income tax and from the special solidarity levy  referred to in Article 43A for 50% of his income from salaried employment acquired in Greece during the tax year.  

This provision can be applied for a total of seven tax years, after which it ceases to apply and the taxpayer will be taxed under the general provisions. It will  also apply for the next tax year, i.e. the one starting from 1/1/2021 onwards.  

We will return on this issue when this provision is voted and the relevant circular is issued by the Ministry of Finance and the Independent Authority for  Public Revenue (IAPR).