Greek–Italian Legal Desk 2026 | Cross-Border Investments, Transactions & Legal Compliance

Tsamichas Law Firm | Studio Legale Atene | Insights

Something structural changed in Greek Italian relations in May 2025. At Villa Doria Pamphilj in Rome, the two governments signed fourteen bilateral agreements and memoranda in a single day, at the first intergovernmental summit in eight years, covering energy, rail, tourism, maritime security, cybersecurity, agriculture and defence. For businesses and investors, that summit was not diplomacy. It was a pipeline of regulated, contract intensive projects that will need to be structured, permitted, tendered, financed and, inevitably, disputed over the coming decade.

Tsamichas Law Firm has spent decades at exactly this intersection. We advised the RENCO TERNA joint venture on the first Microsoft data center in Greece, a €1 billion programme of 19.2 MW pairing an Italian industrial group with a Greek contractor. We supported Hitachi Rail on the Thessaloniki Metro, the first driverless metro in Greece, now carrying passengers daily. We delivered the successful Finmeccanica Tram Serio tender and secured the Industria Italiana Autobus award for 200 CNG buses. This is not a generic claim to cross border capability. The Greek Italian corridor is where our flagship work lives.

Here is our sector by sector reading of where the corridor stands in mid 2026, and precisely what legal work each trend generates.

1. Energy: GRITA 2 and the Making of a Mediterranean Electricity Hub

The headline project is GRITA 2, the new submarine electricity interconnector between Greece and Italy of approximately €1.9 billion and 1,000 MW, agreed between IPTO (ΑΔΜΗΕ) and Terna at the Rome summit and proposed for the EU list of Projects of Common and Mutual Interest. Seabed survey tenders launched in late 2025, with cable and converter station procurement to follow. Athens has publicly stated the ambition to triple electricity interconnection capacity with Italy, cementing the shift of Greece from energy importer to net exporter of green electricity westward.

What this generates legally: supply chain and subcontracting agreements under joint IPTO and Terna procurement; EPC and marine works contracts with Greek permitting layers, including environmental terms and coastal zone (αιγιαλός) approvals; renewable energy developers positioning capacity around a new 1 GW export route, which means grid connection terms, corporate PPAs and project finance security packages; and questions of cross border electricity trading under the reformed EU Electricity Market Design. We advise Italian EPC contractors, component suppliers and renewables investors across each of these layers, and we know from the Microsoft data center programme how Greek permitting reality interacts with Italian corporate expectations.

2. Transport and Rail: The €760 Million Ferrovie dello Stato Programme

The other pillar of the 2025 summit was rail. The Greek Ministry of Transport and Ferrovie dello Stato agreed a modernisation package of roughly €760 million: over €400 million in Greek network investment plus an Italian commitment of €360 million through Hellenic Train, an FS Group company, for new rolling stock, depots and alignment of the Greek network with Italian railway standards.

What this generates legally: rolling stock supply and maintenance contracts; depot construction and related real estate work; interoperability and railway safety certification under the EU Fourth Railway Package; public procurement strategy and remedies under Law 4412/2016 and the Greek system of precontractual review (ΕΑΔΗΣΥ); and claims management on live infrastructure programmes. Our track record with Hitachi Rail, Finmeccanica and Industria Italiana Autobus means we have already run precisely these workflows, from tender to delivery to dispute, for Italian principals in Greece.

3. M&A and Capital Markets: Deal Flow Meets a Euronext Listed Athens

Greek M&A is being repriced upward. The integration of the Athens Exchange into Euronext plugs Greek issuers into the same pan European infrastructure as the ecosystem of Borsa Italiana, while the investment grade rating of Greece continues to attract strategic and fund capital. Italian industrial and food sector consolidation increasingly looks east, and Greek groups look west.

What this generates legally: bilateral due diligence run natively in both legal cultures; negotiation of share purchase and shareholders agreements bridging Greek corporate law (Law 4548/2018 for the ΑΕ, Law 4072/2012 for the ΙΚΕ) with the mechanics of the Italian S.r.l. and S.p.A.; foreign direct investment screening, now that both countries operate FDI regimes, with the new Greek screening framework a genuine deal timeline item that many Italian acquirers have not yet priced in; merger control; and disclosure processes designed for warranty and indemnity insurance. We also structure Greek Italian joint ventures on the RENCO TERNA model, where governance, deadlock and exit mechanics must survive two corporate law systems.

4. Real Estate and Golden Visa: A Rewritten Rulebook in 2026

No sector has changed faster. The residence by investment framework was overhauled by Law 5100/2024, which introduced tiered thresholds: €800,000 for Attica, Thessaloniki, Mykonos, Santorini and larger islands; €400,000 elsewhere; and €250,000 routes for conversions of commercial property to residential use and for heritage restorations, generally with a minimum area of 120 m². In February 2026, Law 5275/2026 restructured the wider migration and investment framework, and in April 2026 the Ministry of Migration issued Circular 1/2026, the first detailed operational guidance in two years, coupled with an explicit enforcement warning against circumvention schemes and artificial price structures. Meanwhile, short term rental of Golden Visa properties is banned outright, with a €50,000 fine and permit revocation, enforced through the AADE short term rental registry, and VAT on new build purchases remains suspended through 31 December 2026 under Law 5246/2025, a closing window that is materially accelerating buy side decisions this year.

What this generates legally: genuinely forensic due diligence covering Κτηματολόγιο title chains, forest map status and building legality under Law 4495/2017, and now Golden Visa compliance design: which property qualifies, how rental income can lawfully be structured through long term leases of 60 days or more, and whether a two property architecture (one qualifying, one income producing) is the right solution. For Italian private clients we deliver this in Italian, benchmarked against the visura and conformità urbanistica checks they know from home. For hospitality investors we layer in hotel licensing, special spatial planning for tourism and operator and franchise agreements.

5. Tourism and Hospitality: From Summit Statements to Operating Reality

Tourism was elevated to treaty level at the 2025 summit, with Greece and Italy committing to joint work on sustainable tourism, digitalised transport links and even joint police patrols in key tourist destinations. On the ground, the legal environment for tourism investment is tightening in parallel: registration and restriction regimes for short term rentals, sustainability disclosure expectations for hotel groups, and ESG linked financing terms from lenders on both sides of the Ionian.

What this generates legally: resort and marina concession work, structuring of mixed use developments, hotel management and franchise agreements with international operators, employment and seasonal workforce compliance, and increasingly green lease and ESG covenants in hospitality finance.

6. Agro Food and PDO/ΠΟΠ/DOP Products: The New GI Regulation Has Teeth

Greece and Italy are the defining geographical indication economies of the EU: feta and Parmigiano Reggiano, Kalamata and Ligurian oil, Santorini and Prosecco. Since Regulation (EU) 2024/1143 took effect, the GI regime has consolidated into a single rulebook with stronger enforcement, explicit protection online and in domain names, and clearer rules on GIs used as ingredients in processed products, squarely targeting the problem of Greek style and Italian sounding imitations that costs producers in both countries billions annually. The 2025 summit added a bilateral layer: a phytosanitary research pact between the Italian institute CREA and the Benaki Institute in Greece and a standing dialogue on sustainable agriculture and fisheries.

What this generates legally: governance of producer groups and amendments to specifications (προδιαγραφές, disciplinare); PDO and PGI enforcement against evocation and imitation, including platform takedowns and customs actions; licensing of protected names within distribution, private label and franchising structures; export contracts with EU food information and labelling compliance; and, for agri industrial groups, supply chain due diligence under the EU Deforestation Regulation as its application phases in.

7. Tax: Two Competing Non Dom Regimes and a Moving EU Framework

Greece and Italy are now direct competitors for mobile wealth. The Italian flat tax for new residents rose to €200,000 per year, while the Greek non dom regime holds at €100,000, alongside the 7% regime for foreign pensioners and the 50% exemption on employment income for relocating professionals. The relocation analysis between Athens and Milan has become a live, quantifiable exercise for high net worth families. At the corporate level, Pillar Two minimum taxation is in force in both countries, the VAT in the Digital Age (ViDA) package is phasing in obligations for platforms and e invoicing, and the Greek myDATA regime already gives Italian groups a taste of the real time tax reporting their home CFOs know from the Italian SDI system.

What this generates legally: residence relocation planning with exit tax and treaty tie breaker analysis under the Greece Italy double taxation treaty; permanent establishment risk reviews; corporate transformations under Greek tax incentive laws aligned to Italian group structures; transfer pricing documentation; and VAT structuring for cross border e commerce and platforms.

8. Family Office, Wills and Succession: Regulation 650/2012 in Practice

The Greek Italian family with a Milan apartment, an olive estate in the Peloponnese and children in a third country is our daily reality. Under the EU Succession Regulation 650/2012, habitual residence determines the applicable law unless a national law is validly chosen in a will, and the interaction between Greek forced heirship (νόμιμη μοίρα) and the Italian legittima is where unadvised estates come apart.

What this generates legally: cross border wills compliant in both systems, with choice of law clauses; European Certificates of Succession; proceedings for acceptance of inheritance and inheritance tax filings in Greece for Italian heirs; family office and holding structures for entrepreneurial families with assets in both states; and governance frameworks for the generational transition of operating businesses.

9. Technology, Telecoms and AI: The Compliance Clock Is Running

The 2025 summit included a dedicated cooperation agreement on cybersecurity and digitalisation, and the EU layer is where the real work now sits. The obligations of the EU AI Act for general purpose AI are already live, with the high risk regime phasing in from August 2026, subject to the pending Digital Omnibus adjustments that every compliance team is tracking. NIS2 cybersecurity obligations have been transposed into Greek law, capturing operators in energy, transport and digital infrastructure, precisely the sectors driving Greek Italian projects. Add DORA for financial entities and the Data Act, applicable since September 2025, and technology counsel has become infrastructure counsel.

What this generates legally: classification of AI systems and conformity roadmaps for providers and deployers in both markets; NIS2 scoping and incident response frameworks; telecoms regulatory work before the Greek regulator EETT with coordination toward counsel facing the Italian regulator AGCOM; data governance and GDPR programmes; and technology transactions for companies scaling between Athens and Milan. Our AI governance and LegalTech practice advises on these frameworks because we implement them in our own operations.

10. Environment and ESG: After the Omnibus, Strategy Beats Box Ticking

The EU CSRD and CS3D Omnibus simplification has reshuffled which companies report and when, but it has not changed the direction of travel. Lenders, insurers and major counterparties on Greek Italian projects contractually require sustainability data regardless of statutory thresholds. Meanwhile CBAM enters its definitive regime in 2026, directly affecting flows of cement, steel, aluminium and fertilisers through the Adriatic and Ionian trade lane.

What this generates legally: analysis of double materiality and reporting scope after the Omnibus; environmental permitting and impact assessment (ΜΠΕ) work for energy, tourism and industrial projects; CBAM registration and declaration support for importers; and ESG clauses in finance and supply agreements.

11. Disputes and Enforcement: When the Corridor Litigates

More deals mean more disputes. We enforce Italian judgments in Greece and Greek titles in Italy under the Brussels I bis Regulation without exequatur, run European Orders for Payment and cross border debt recovery, arbitrate construction and supply disputes on infrastructure programmes, and defend or prosecute precontractual tender challenges, an area where speed and procedural precision decide outcomes.

Why Clients Bring Greek Italian Matters to Tsamichas

Subject matter expertise on this corridor is verifiable, not asserted. It is the RENCO TERNA Microsoft data center mandate. It is Hitachi Rail on the Thessaloniki Metro. It is the winning tenders of Finmeccanica and Industria Italiana Autobus. It is a team that reads Law 5275/2026, Circular 1/2026, Regulation 2024/1143 and the AI Act implementing acts as they publish, in Greek, Italian and English, and converts them into transaction structure the same week. From our Athens offices at Akadimias and Voukourestiou, and through italia.gr and our network of Italian counsel, we operate as one desk across both systems.

Our Relevant Services

Energy and Infrastructure. RES licensing and PPAs, EPC and construction contracts, advisory on data centers and interconnector related projects, project finance support, EU energy regulation.

Public Procurement and Tenders. Bid strategy and documentation for Greek public tenders, precontractual remedies before ΕΑΔΗΣΥ and the courts, concession and contract management, claims on infrastructure programmes.

Corporate, M&A and Joint Ventures. Due diligence, share and asset deals, shareholders agreements, FDI screening and merger control filings, structuring of Greek Italian joint ventures, corporate governance.

Real Estate and Golden Visa. Full scope acquisition due diligence, notarial completion and tax registration, Golden Visa structuring and compliance under Law 5100/2024 and Law 5275/2026, hotel and tourism licensing.

Tax and Corporate Structuring. Choice of vehicle, corporate transformations under Greek incentive laws, treaty and transfer pricing advice, non dom and relocation planning for individuals, VAT and myDATA compliance.

Agro Food, PDO/ΠΟΠ Licensing and Distribution. GI registration, specification and enforcement work under Regulation 2024/1143, licensing of protected names, distribution, agency and franchise agreements, food labelling compliance.

Intellectual Property. EU and national trademarks and designs, copyright including for digital creators, licensing, anti counterfeiting enforcement, IP due diligence in transactions.

Technology, Telecoms, Data and AI. AI Act readiness, NIS2 and DORA compliance, GDPR and data governance, telecoms regulatory work before EETT, technology transactions.

Environment and ESG. Environmental permitting and impact assessments, CSRD scoping after the Omnibus, CBAM support, ESG contract clauses and sustainability governance.

Family Office, Wills and Succession. Cross border wills and choice of law planning, European Certificates of Succession, Greek inheritance proceedings for foreign heirs, family office and holding structures.

Transportation and Maritime. Rail, road, aviation and shipping regulatory advice, rolling stock and fleet contracts, cargo and charter disputes on the Adriatic and Ionian routes.

Dispute Resolution and Enforcement. Litigation and arbitration, enforcement of foreign judgments and awards in Greece and Italy, European Orders for Payment, cross border debt recovery.

Speak to the Greek Italian Desk

If your business, family or project touches both shores of the Ionian, speak with counsel that has already built on this corridor.