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Moving a family is not moving a postcode

When a household relocates, the questions are practical: schools, housing, a new bank account.  The move touches every layer of its legal and financial architecture at once. In our work with private clients, we see the same set of questions arise every time:

• Which country will treat the family as tax resident, and from when?
• What will the country being left behind still claim, at departure and afterwards?
• How will companies, trusts, portfolios and property be held after the move?
• Which law will govern succession, and will it respect the family’s wishes?
• Where will the family actually want to live, work and raise children?

These questions cannot be answered one at a time. A residence decision changes the tax outcome, the tax outcome shapes the holding structure, and the holding structure determines how wealth passes to the next generation. A relocation planned in the right order can protect a family’s position for decades. The same relocation, planned in the wrong order, can create exit charges, double taxation and succession disputes that take years to resolve. This research note sets out how Tsamichas Law Firm approaches the question in the European context, why Greece has become one of the most frequently considered destinations, and where we most often see value preserved or lost.

Europe’s options have narrowed

Only a few years ago, families looking south had a comfortable menu of preferential regimes. Since 2024, almost every item on that menu has been withdrawn, restricted or repriced. Our review of the main competing jurisdictions shows a clear pattern:

• United Kingdom: the non domiciled regime ended in April 2025, and the UK now taxes on the basis of residence alone
• Portugal: the Non Habitual Resident regime was closed to newcomers; its successor, IFICI, is limited to a short list of research and innovation roles and offers little to investors or retirees
• Spain: the inbound worker regime survives, but it depends on an employment relationship and leaves passive wealth within reach of Spanish wealth taxes
• Italy: the lump sum for new residents has risen from €100,000 in 2017 to €200,000 in 2024 and to €300,000 a year for arrivals from January 2026, with €50,000 for each family member
• Cyprus: the non domiciled status remains available for seventeen years and suits dividend and interest income, though it is less flexible for families with complex global holdings

Italy’s trajectory is the most revealing. The regime has not been abolished; it has been repositioned as a premium product for a small number of very wealthy households. For a family with significant but not exceptional foreign income, the annual cost now changes the calculation entirely.

Greece stands out against this background for two reasons. The first is price. The second, which our clients increasingly value, is stability: the Greek figures have not changed since the regimes were introduced, and for a plan intended to run for fifteen years, predictability is worth almost as much as the rate itself.

Three Greek regimes, three different families

Greece did not create one regime for everyone. Articles 5A, 5B and 5C of the Income Tax Code (Law 4172/2013) each target a distinct profile. In our practice, the first and most important decision in any Greek relocation is matching the family to the right article.

Article 5A: for investors with substantial foreign income

Article 5A is the regime that draws international attention. A person who moves tax residence to Greece replaces Greek tax on all foreign source income and gains with a single €100,000 annual payment, however large that income may be. Its main features:

• €20,000 a year for each relative who joins the regime
• a maximum duration of fifteen tax years, without extension
• foreign assets kept outside Greek inheritance and gift tax while the regime applies
• Greek source income taxed under the ordinary rules

Entry has two conditions. The applicant must not have been Greek tax resident in seven of the previous eight years, and must invest at least €500,000 in Greece within three years of applying, whether in property, businesses, securities or Greek companies. For a family whose foreign income runs into seven figures, the comparison with Italy’s €300,000 charge speaks for itself.

Article 5B: for retirees

Article 5B is designed for foreign pensioners and is, in our experience, often underestimated. It applies a 7% rate to all foreign source income, including dividends, interest, rents and gains as well as pensions, for up to fifteen years. The key conditions:

• no Greek tax residence in five of the previous six years
• relocation from a country that has a tax cooperation agreement with Greece
• no minimum investment
• continued access to double tax treaty protection

For retirees with diversified but moderate portfolios, 5B frequently produces a better result than 5A.

Article 5C: for professionals and founders

Article 5C serves people who come to Greece to work or to build a business. It exempts half of their Greek employment or business income from tax for seven years, provided they were not resident in five of the previous six years, take up a new role or activity in Greece, and commit to staying for at least two years. For executives, entrepreneurs and members of the Greek diaspora returning home, it is often the most valuable of the three.

One rule applies to all of them: if the annual amount is not paid in full and on time, the regime is lost and worldwide income is taxed under the general rules from that year onwards. Administration matters as much as structure.

The right to live in Greece is a separate matter

A misunderstanding we encounter regularly is the assumption that a tax regime brings with it the right to reside. It does not. Electing into Article 5A gives a non EU national no residence rights, and a residence permit gives no tax benefit on its own. EU and EEA citizens can rely on free movement; families from the United States, the United Kingdom, the Gulf or Asia generally need a permit before the tax planning can begin.

For many of them, the route is the Greek Golden Visa, which was substantially reformed by Law 5100/2024. The old single €250,000 threshold no longer exists. Real estate investment now qualifies at three levels:

• €800,000 for one property in Attica, Thessaloniki, Mykonos, Santorini or any island with more than 3,100 residents
• €400,000 for one property anywhere else in Greece
• €250,000 only where a commercial building has been converted to residential use before the application, or where a listed building is restored

The reform also brought new conditions:

• a minimum floor area of 120 square metres for the two higher tiers
• a ban on short term letting of the qualifying property
• revocation of the permit and a €50,000 fine for breach

Two practical lessons follow from our files. First, the property purchase and the €500,000 investment required under Article 5A should be designed together, so that one well structured investment serves both purposes wherever the rules allow. Second, a property advertised as “Golden Visa eligible” has no special legal status. Title, zoning, building permits, encumbrances and permitted use must be verified independently before any deposit is paid, because a defect found after completion can undermine both the permit and the tax regime built on it.

Where relocations go wrong

In the matters we have handled, relocations seldom fail because someone misread a tax rate. They fail because steps were taken out of order, or because one part of the move was planned without regard to the others. The risks fall into four groups.

Leaving the old country. Several jurisdictions charge departure taxes or treat assets as sold on emigration, and some continue to tax former residents for years afterwards. A family that settles in Athens before its exit is properly handled may find the old jurisdiction still has a claim. A clean departure is as important as a good arrival.

Choosing the wrong regime. Article 5A is powerful for large foreign incomes, but because foreign tax is not credited against the Greek lump sum, the effect of withholding taxes in source countries must be modelled first. In practice:

• substantial and varied foreign income usually points to 5A
• pension and moderate investment income usually points to 5B
• an active career or business in Greece usually points to 5C
• in some cases, the ordinary Greek rules turn out to be the best answer

Establishing genuine residence. Greek tax residence depends on a permanent home, a centre of vital interests, or more than 183 days of presence in a year. Applications for the special regimes are tied to the year of transfer and have strict deadlines. Funds brought into Greece must be supported by clear evidence of their origin, which banks and the tax authorities will examine carefully.

Managing the long term. Several issues only appear once the family has settled:

• automatic exchange of financial information and European beneficial ownership registers mean every structure must withstand full disclosure
• succession planning must reconcile the reserved shares Greek law gives close relatives with the choice of law allowed under the EU Succession Regulation (650/2012)
• gains on Greek property are ordinarily taxed at 15%, a charge currently suspended until 31 December 2026
• a fifteen year regime will outlast several tax reforms, so regular reviews should be part of the plan from day one

Greece as a plan, not a rate

In 2026, the case for Greece is strong. As neighbouring regimes have closed, narrowed or become more expensive, Greece offers:

• a fixed €100,000 lump sum that has not changed since its introduction
• dedicated regimes for retirees and for working professionals
• full membership of the European Union and the Schengen area
• a quality of life that, for many families, weighs as heavily as any tax figure

Our conclusion, however, is that the real advantage never lies in the headline number. It lies in treating tax, residence, property, succession and family life as one coherent plan, executed in the right order.

Tsamichas Law Firm has advised international clients from Athens since 1991. Our private client and tax practice supports families and family offices at every stage:

• selecting and applying for the 5A, 5B or 5C regime, and keeping it in good standing
• residence permits, Golden Visa structuring and full property due diligence
• documenting the source of funds and the lawful transfer of foreign capital
• holding structures, family governance and succession planning
• coordination with accredited accountants and with our clients’ advisors abroad