Tsaks Consulting Greece

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US to Greece tax residency and wealth relocation services

Our cross-border advisory service for US HNWIs, Fund Managers & Family Offices

High Net Worth Individuals (HNWIs), private equity executives, tech founders, and family offices based in the US are increasingly re-evaluating their global residency options. In recent years, with the introduction of favourable tax incentives through the Greek Tax Code, Greece has emerged as an attractive tax destination option and a logical alternative to Dubai, Singapore and other countries. Our cross border advisory team assists clients from the US to assess their options in Greece and make the move whilst taking advantage of Articles 5A, 5B and 5c of the Greek income tax code. This extends to securing Greek Tax residency.

We work closely with clients and our accounting partners to:

  • Advise clients on the best options.
  • Provide a responsive, English speaking service.
  • Understand the Greek non-dom incentives and how they comply with complex US Internal Revenue Code (IRS) and Foreign Tax Credit (FTC) requirements.

Tsaks Consulting expertise

  • 10 years experience advising US based clients on moving to Greece
  • Full service relocation advisory firm with strong in-house expertise as well as partnerships with leading lawyers and accountants
  • Cross-border presence and specialisation in implementing favourable tax regime

The Greek alternative tax regimes for US Investors

Greece’s foreign investment incentives offer guaranteed tax stability backed by national law. These include:

1. Article 5A: The Lump-Sum Non-Dom Regime for High-Net-Worth Investors

Designed for global investors transferring their primary tax domicile to Greece:

  • €100,000 Annual flat tax: This flat-tax amount replaces progressive Greek income tax on foreign-sourced income, capital gains, foreign dividends, and investment yields—regardless of total earnings globally.
  • Family office coverage: This scheme extends non-dom protection to immediate family members for an additional €20,000 per relative per year.
  • Exemption from Gift & Estate Taxes: Foreign-held assets, foreign real estate, and overseas investment accounts remain 100% exempt from Greek gift and inheritance taxes.
  • 15-Year Statutory Guarantee: This scheme locks in regime eligibility for up to 15 fiscal years.
  • Qualifying Investment Requirement: Requires a minimum €500,000 investment into Greek real estate, corporate equity, or government/corporate securities within 3 years.

✍️ Thoughts from our Director – Dimitrios

“In my experience, there are a number of different factors to consider. We generally find that complying with Article 5A is the easy and straight forward part although our accounting partners will advise on this. However, you need to plan your major sales and other capital gains triggering actions in the US and the relevant timing of them. You need to consider your IRS tax positioning and pay careful attention to how this affects your position moving to Greece. There are also benefits to consider with alternative tax investments as opposed to purchasing real estate as many clients find the real estate acquisition process in Greece too complicated. We also find it’s important to consider your family and life plans and the benefits of extending the scheme across your family. The article 5A process is beneficial for HNWIs and requires careful planning for your life and set-up in Greece. The timing of your distributions and tax transfers is also important, particularly with respect to which specific tax year.”

2. Article 5C: Executives, Tech Founders & Fund Manager Incentives

An excellent opportunity for US founders, asset managers are executives who are able to work remotely and relocate to Greece. The key advantages include:

  • 50% Income tax waiver: There is an exemption from Greek progressive income tax on 50% of Greek-sourced salary or business income for 7 consecutive years.

  • Asset & found management structuring: There are compliant tax routes for private equity partners and fund managers establishing regional management entities in Athens.

     ✍️ Thoughts from our Director – Dimitrios

      “This is very popular for individuals to move to Greece and take advantage of the tax break. In our experience, it’s very popular and provides a long term tax incentive which is great. A lot        of our clients end up establishing businesses work or work as freelancers from Greece and this helps them be eligible if they don’t have a full time job in Greece. It’s highly popular as it is              uncapped meaning the 50% reduction applies to any amount that you earn. Although, when you are a high-net work individual the Article 5A is generally more suitable. An advantage of          5C is the application process is relatively simple, quick and easy.”

Specialized US-Greece Cross-Border Tax & IRS Compliance

The US is different to most other jurisdictions as US citizens and Green Card holders remain subject to US federal taxation on worldwide income. Merely moving to a non-dom country does not end IRS filing obligations and this needs to be considered when undertaking a move. Our team of advisors work with experts in the US and Greece to ensure your structure complies with US international tax codes and can assist with:

  • Foreign tax credit (FTC) optimization: Structuring Article 5A lump-sum tax payments and Article 5B flat taxes against your IRS Form 1116 filings to prevent double taxation.

  • Entity structuring (PFIC & CFC Rules): Structuring local Greek corporate vehicles, holding entities, and real estate SPVs to avoid punitive Passive Foreign Investment Company (PFIC) or Controlled Foreign Corporation (CFC) tax rates under the US Tax Code.

  • State tax exit planning: Assisting HNWIs leaving high-tax US states (such as California, New York, or New Jersey) to establish statutory residency ties in Greece and establish a clean US state tax break.

  • FATCA & FBAR compliance: Full alignment across Foreign Bank Account Reporting (FBAR / FinCEN 114) and foreign financial disclosures (Form 8938).

✍️ Thoughts from our Director, Dimtirios 

“The most significant challenge and issues clients face are generally to do with state-level exit planning. We always make sure we work with expert accounting and tax firms in each state in order to provide tailored advice to clients in different cities and states such as California and New York. We also make sure you take a highly detailed approach to federal tax treaties and post-move tax obligations in the US.”

Why Partner with Tsaks Consulting?

  • In-House dual legal & accounting: Our attorneys and tax accountant partners work together with our advisory team, eliminating misalignments between your tax declarations and legal contracts.

  • Cross-border focus: We specialize exclusively in cross-border wealth migration, with comprehensive knowledge of the US-Greece Double Tax Treaty (DTT).

  • No travel required: Our team assist with complete real estate transfers, bank account setups, and tax registrations remotely via Power of Attorney (POA).

  • Direct access across major US Hubs: Our team regularly meets private clients and family offices face-to-face in New York, Boston, Chicago, Miami, Los Angeles, and San Francisco.

Talk to our team at Tsaks Consulting

Managing a cross-border relocation between the United States and Greece requires clear strategy and strict compliance. Talk to our private client advisory team today to discuss Article 5A non-dom status, wealth structuring, or luxury real estate acquisitions in Greece and how we can be of assistance.