Greece

EMET works with several recurring Greek relocation profiles.

Capital holder with a Swiss-booked investment portfolio. A client with €5-15M+ at a Swiss private bank, no active operating business, living on dividend and interest income. Greece as a place of residence — climate, culture, EU residence; the tax side is handled under the standard regime or, where the portfolio is large enough, under 5A. The acquisition of Greek real estate (an apartment in Athens, a property on Corfu or Mykonos) serves as the place of residence and, where relevant, as the instrument that satisfies the Golden Visa and the 5A investment criterion.

Client with international rental real estate. The client holds a portfolio of rental property across several jurisdictions (Spain, Germany, Russia, occasionally Cyprus). Greece is the consolidation point for tax residency. For sizeable rental income (where the progressive scale becomes heavy) the 5A regime can cover it within the single fixed amount of €100,000; at more moderate volumes the standard regime is usually more efficient.

Family relocation through the Greek Golden Visa. The family relocates with school- or teen-age children — driven by lifestyle and education considerations alongside EU residence. Where the family elects 5A, the principal applicant pays €100,000 and family members €20,000 each on top; the configuration delivers fifteen-year predictability across every member provided the combined portfolio justifies the fixed payment. Otherwise the family remains on the standard regime.

Pre-relocation diagnostic without commitment. The client is considering Greece alongside other directions (Italy, Cyprus, Portugal) — analysis of 5A against the standard regime, against the Italian forfait, against the Cypriot non-dom regime. A diagnostic format: EMET handles the analysis without commitment to relocation.

The Greek Golden Visa and Article 5A are two distinct mechanisms operating at different levels — one provides a residence right, the other a tax status — and for Russian-speaking clients they are typically satisfied by a single transaction.

The Greek residence-by-investment programme, often called Golden Visa, grants a residence right but does not automatically establish tax residency. These are two distinct layers — immigration and tax. EMET therefore tests, before the choice of property, not only the investment route itself but whether the family's actual living scenario will result in Greek tax residency, and how this aligns with the 5A regime.

Interface with 5A. A Greek Golden Visa investment of €800,000 in a high-demand zone typically also covers the 5A €500,000 investment criterion — one transaction can satisfy both requirements. At €400,000 in the other regions an additional €100,000 investment is required for 5A. Without the Golden Visa, the 5A regime is available to individuals with EU citizenship or another route to EU residency.

The client's citizenship is not an administrative detail but a question of route admissibility. Before any conversation about the choice of property, the residence-by-investment programme or the 5A regime, EMET tests whether the client can in principle proceed under the Greek investor route, which nationality is used in the application, how source of funds is supported, and whether any sanctions or banking block arises. For clients with dual citizenship one route may be available; for clients with Russian citizenship alone the fork appears before the transaction, not after the filing.

The standard regime is the default regime for Greek residents and the working answer for the majority of EMET's Greek clients. 5A is applied as the exception — either where the fixed payment genuinely breaks even on the client's portfolio, or where the client's profile otherwise calls for fixed predictability. In all other cases the standard regime applies.

Personal income tax is calculated on a progressive scale on worldwide income, with marginal rates running up to 44% in the upper band. Dividends and interest are taxed at preferential fixed rates — typically 5% on dividends and 15% on interest. Capital gains on financial assets are taxed at preferential rates of approximately 15%, depending on the structure of holding and the type of asset.

Greek real estate carries its own annual tax — ENFIA, the unified property tax. This is the part of the residency burden almost always underestimated by the client until the first tax year: ENFIA rarely drives the choice of Greece itself, but routinely changes the final economics on a specific property. For EMET clients buying within the residence-by-investment programme in high-demand regions — Attica, central islands — this means the annual ENFIA burden has to be priced into the total cost of ownership from the outset, not appear as a surprise.

The solidarity surcharge has historically applied to a broader range of income; in the current configuration its application is narrower and depends on the category of income. A standard Greek resident is required to declare all worldwide income on the annual return (form E1) through the AADE TAXISnet system.

The Greek tax position never works in isolation — it intersects with other elements of the client's structure.

The Russian side. EMET runs the Russian side for every client with a Greek tax position: Russian CFC reporting (where the client retains Russian tax residency or sits in transitional years between statuses), foreign-account disclosures, currency-control filings, and preparation of responses to Russian tax-authority enquiries. The central task is a consistent position across jurisdictions, in which the Russian and Greek sides do not contradict each other.

CFC structures (Cyprus, Seychelles, BVI) with Swiss-booked accounts. Greek CFC rules apply to controlled foreign companies with passive income in low-tax jurisdictions. For offshore structures (Seychelles, BVI) the treatment is stricter — a look-through approach to income, substance requirements, and a wider scope of taxation of undistributed profit. For a Cyprus holding structure the analysis depends on the type of income and the substance present; the regime differs from the offshore treatment. On the Russian side the obligations on CFC notification and on filing of the controlled company's financial statements with the Russian tax authority arise where the client retains Russian CFC status.

Swiss banking infrastructure. Most EMET clients with a Greek relocation profile hold the bulk of their capital with Swiss private banks (UBP, Edmond de Rothschild, Pictet, Lombard Odier). Consistency of KYC and source-of-funds across all of the client's banks — Swiss, Greek operational accounts, holding-structure corporate accounts, residual Russian — is a central part of EMET's work. Holding assets across multiple jurisdictions intersects with CRS reporting, beneficial-ownership disclosure, and source-of-funds review at the bank level; EMET ensures consistency of the position the client maintains across all of their bank relationships.

The Russia-Greece treaty after 2023. The peculiarity of the Greek situation is that the effect of the Russian suspension depends heavily on the chosen regime. For a 5A resident, foreign income is largely covered by the fixed payment and the interaction with Russian-source dividends or interest through ordinary withholding-credit mechanics becomes less central. For a standard Greek resident the picture is the opposite: any material Russian-source payment requires a separate analysis. This affects not only the choice of regime but how 'real' the role of the treaty remains in the client's current configuration.

Configuration A — Standard Greek resident with assets outside Greece (the most common configuration)

The client holds assets at Swiss private banks, in a Cypriot or offshore holding, sometimes with Russian real estate; portfolio in the €3-15M range. Foreign-source passive income does not reach the 5A breakeven, or the client's profile does not meet the 5A entry conditions. EMET runs the Greek side under the standard regime: the annual return (form E1) with proper computation of worldwide income and application of the Greek flat rates on foreign passive income (dividends 5%, interest and capital gains 15%), ENFIA on Greek real estate, coordination with the Swiss banks, the Russian side (CFC compliance, currency control).

Configuration B — Capital holder on the 5A regime through the Greek Golden Visa

The client holds a portfolio of €15-25M+ at a Swiss private bank, with foreign-source investment income in the region of €1M+ per year (or a mixed profile with a meaningful share of active, rental or royalty income). Acquisition of a residence on Mykonos or an apartment in Athens for €800k through the Golden Visa, relocation, and activation of 5A. The fixed payment of €100k replaces a heavier burden under the standard regime. EMET handles: 5A filing with AADE, the annual return, coordination with the Swiss banks, Russian CFC reporting.

Configuration C — Family configuration on 5A

The client relocates with spouse and two children through the Greek Golden Visa; the portfolio reaches the 5A breakeven. Principal applicant — €100k; spouse and children — €20k each: €160k fixed for the entire family. EMET handles the family filing, the annual return, and coordination with the Russian side for each family member individually (tax residency is assessed individually).

Configuration D — Pre-relocation comparative analysis

The client is considering Greece alongside other EU directions. EMET runs a diagnostic comparison of 5A against the standard Greek regime, against the Italian forfait, against the Cypriot non-dom — on the client's specific numbers. This is work without commitment to relocation; in a substantial share of cases the outcome of the analysis is the choice of a different jurisdiction or the retention of the existing residency status.

Configuration E — Multi-jurisdictional: 5A resident with a CFC and Swiss-booked accounts

A Greek 5A resident owns a Cypriot or Seychelles CFC with accounts at Swiss private banks. EMET runs all layers: the Greek side (5A filing, application of Greek CFC rules), the Russian side (where applicable), and Swiss banking coordination.

EMET runs the strategic and coordination side of the work. Filings to AADE are prepared and submitted by EMET directly through the client's tax profile — the Greek Tax Identification Number (AFM). Where the client does not yet hold an AFM, EMET assists in obtaining it and establishing communication with the tax authority through the TAXISnet system. A local Greek certified accountant or tax counsel is engaged as a separate specialist layer in complex situations — corporate reporting for Greek entities, specific audit work, non-standard treaty positions — not as a mandatory intermediary.

This is an engagement format close to a multi-family office: the annual return is only one element of the ongoing work on the client's position. The principal value is regular coordination of the position throughout the year.

The standard engagement cycle runs through four phases.

1. Structural positioning

Review of the existing or planned configuration: 5A versus standard regime breakeven analysis on the client's specific profile, coordination of the Greek Golden Visa with the 5A filing, the Greek residency position, existing holding structures (Cyprus, BVI, Seychelles). Russian CFC implications where the client retains Russian CFC status.

2. Establishing the tax profile (5A or standard regime)

Obtaining the AFM, registering the residency position with AADE. Where the client elects 5A, the application is filed within the prescribed window (by 31 March of the year following the year of becoming a resident), with handling of the tax authority's reviews and enquiries. For the standard regime, the annual return cycle (form E1) is set up without a separate 5A filing. Engaging a local accountant where needed.

3. KYC and source-of-funds coherence

A consistent source-of-funds logic across all of the client's banks — Swiss, Greek operational, holding-structure corporate, residual Russian. Documentation consistency across jurisdictions. Preparation for bank and regulatory enquiries as a single coherent position.

4. Annual engagement and long-term planning

The annual Greek return (form E1) under the chosen regime — 5A or standard. Coordination with the Swiss banks across the year. Russian CFC reporting. At years 13-14 of the 5A application — preparation for the transition to the standard regime at the end of the fifteen-year period. Coordination with offshore CFC structures across both jurisdictions.