Greece’s AADE had issued Decision A. 1192/2026, setting out the procedures and requirements for foreign pensioners transferring their tax residency to Greece under Article 5B of Law 4172/2013. The decision had confirmed the 7% flat tax, eligibility conditions, application deadlines and documentation requirements.
Greece’s Independent Authority for Public Revenue (AADE) had issued Decision A. 1192/2026 on 22 September, 2026, setting out procedures and requirements for foreign pensioners transferring their tax residency to Greece under Article 5B of Law 4172/2013 (Income Tax Code).
Published in FEK B’ 5767/24.9.2026, the decision replaced Joint Ministerial Decision A. 1217/2020 and established the conditions for applying the special tax regime.
Tax treatment
Qualifying foreign-sourced income is subject to a 7% flat tax for up to 15 consecutive tax years, starting from the tax year in which the application is submitted. Payment of the tax exhausts Greek income tax obligations on the covered foreign-sourced income.
Foreign taxes paid on eligible income may be credited against the Greek 7% tax, subject to the applicable Double Taxation Agreement (DTA) or, where no DTA exists, the relevant rules. Any excess foreign tax is not refundable.
Greek-sourced income, including real or imputed income, remains subject to the standard Greek income tax rates.
Tax payment rules
The annual 7% tax must be paid in one instalment by the last working day of December. The amount cannot be offset against other tax credits or paid under an instalment arrangement.
Failure to pay the full tax by the deadline automatically revokes the special regime for that tax year and subsequent years. The taxpayer then becomes subject to the standard worldwide income taxation rules in Greece.
Eligibility requirements
To qualify under Article 5B, an individual must:
- receive foreign pension income from mandatory public insurance, legally established occupational funds or group pension insurance policy payouts;
- not have been a Greek tax resident for 5 out of the 6 years preceding the transfer of tax residency;
- transfer tax residency from a state with an active agreement on international administrative tax cooperation with Greece; and
- not simultaneously participate in the Article 5A non-dom investor regime.
Application procedure
Applications are handled by KE.FO.D.E. Attica (Section A8′) or KE.FO.D.E. Thessaloniki (Section A5′), depending on the applicant’s jurisdiction.
Individuals transferring their tax residency on or before July 2 may apply in the year of arrival or the following year. Those transferring residency after July 2 may apply in the following tax year.
The application must be filed by October 31 of the relevant year. Supporting documents unavailable at the time of filing may be submitted by November 30 of the same tax year.
Applications and supporting documents may be submitted digitally through the myAADE portal using “Ta Aitimata mou”, by registered mail or courier, or in person by appointment through “Ta Rantevou mou”.
AADE must review applications and issue a decision within 60 days of filing and no later than the last working day of December.
Required documents
Applicants must provide official documentation from a foreign pension fund, public authority or insurance provider confirming payment of pension benefits.
Tax residency history may be verified automatically where AADE records establish foreign tax residency for 5 out of 6 preceding years, or where the individual is applying for a Greek Tax Identification Number (TIN) for the first time.
Where automatic verification is not possible, applicants must provide documents such as Tax Residence Certificates, official DTA application forms, foreign tax returns or assessments, or certifications from foreign authorities.
Foreign public documents generally require legalisation through an Apostille or consular certification and an official Greek translation, subject to specified exemptions.
Revocation and family members
Taxpayers may voluntarily leave the regime by submitting a revocation request by October 31 of any tax year. After revocation, the taxpayer returns to the general tax rules and cannot re-apply under Article 5B.
The transfer of tax residency under Article 5B applies only to the applicant and does not automatically change the tax residency status of related family members.
This structure separates tax treatment, payment rules, eligibility, application procedure, documentation, and revocation, while keeping the legal terminology and details intact.
