Tsaks Consulting Greece

Legal, Accounting and Company formation for expats in Greece.

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 consultancy and advisory coordination team assists clients from the US to assess their options in Greece and make the move whilst considering the advantages available under Articles 5A, 5B and 5C of the Greek Income Tax Code. This extends to securing Greek tax residency, with specialist tax and legal advice provided by our independent professional partners.

We work closely with clients and our independent accounting partners to:

  • Advise clients on the available options through our consultancy services and independent qualified professionals.
  • Provide a responsive, English-speaking service.
  • Understand the Greek non-dom incentives and how they interact with complex US Internal Revenue Code (IRS) and Foreign Tax Credit (FTC) requirements, with specialist advice from independent US and Greek tax professionals.

Tsaks Consulting Expertise

  • 10 years’ experience assisting US-based clients with moving to Greece.
  • Full-service relocation consultancy with strong business advisory expertise as well as partnerships with leading independent lawyers and accountants.
  • Cross-border presence and specialisation in coordinating applications for favourable tax regimes.

The Greek Alternative Tax Regimes for US Investors

Greece’s foreign investment incentives offer tax advantages and a degree of statutory stability, subject to eligibility requirements and applicable law. These include:

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

Designed for global investors transferring their tax residence to Greece:

  • €100,000 annual flat tax: This flat-tax amount replaces the ordinary Greek income tax treatment of qualifying foreign-sourced income, including foreign dividends, capital gains and investment yields, regardless of the total amount of qualifying foreign income. Greek-sourced income remains subject to the applicable Greek tax rules.
  • Family office coverage: This scheme can extend the alternative taxation treatment to qualifying family members for an additional €20,000 per relative per year.
  • Exemption from gift and inheritance taxes: Qualifying assets located outside Greece may benefit from an exemption from Greek inheritance and gift taxes, subject to the applicable statutory requirements.
  • 15-year statutory period: The scheme is available for up to 15 tax years, provided the eligibility requirements continue to be satisfied.
  • Qualifying investment requirement: Generally requires a minimum €500,000 qualifying investment in Greece, such as real estate, corporate equity or eligible securities, within the prescribed period, subject to statutory conditions and any applicable exceptions.

Thoughts from Our Team

“In our experience, there are a number of different factors to consider. We generally find that complying with Article 5A can be relatively straightforward, although our independent accounting partners will advise on the specific requirements. 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 when moving to Greece. There are also benefits to consider with alternative qualifying 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 eligible HNWIs and requires careful planning for your life and setup in Greece. The timing of your distributions and tax transfers is also important, particularly with respect to which specific tax year applies.”

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

An excellent opportunity for eligible US founders, asset managers and executives who are able to relocate to Greece and meet the applicable employment or business activity requirements. The key advantages include:

  • 50% income tax exemption: There is an exemption from Greek income tax on 50% of qualifying Greek-sourced employment or individual business income for 7 consecutive tax years, subject to eligibility requirements.
  • Asset & fund management structuring: There may be compliant tax routes for private equity partners and fund managers establishing regional management entities in Athens, depending on their activities, business structure and individual circumstances.

Thoughts from Our Team

“This is very popular for individuals looking to move to Greece and take advantage of the tax break. In our experience, it provides a long-term tax incentive which is attractive. A lot of our clients end up establishing businesses or working as freelancers from Greece, and this may help them become eligible if they don’t have a full-time job in Greece, provided they meet the relevant requirements. It’s highly popular as the 50% exemption is not generally subject to a fixed income cap. Although, when you are a high-net-worth individual, Article 5A may be more suitable depending on your circumstances. An advantage of 5C is that the application process can be relatively simple and straightforward for eligible applicants.”

Specialized US-Greece Cross-Border Tax & IRS Compliance

The US is different from most other jurisdictions as US citizens and Green Card holders generally 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 consultancy team works with independent tax and accounting experts in the US and Greece to help clients understand their obligations and coordinate appropriate cross-border structuring and compliance advice. This can include:

  • Foreign tax credit (FTC) optimisation: Assessing the treatment of Article 5A lump-sum tax payments and Article 5B taxes in relation to IRS Form 1116 filings and potential double taxation. The availability and amount of any US foreign tax credit depend on the applicable US tax rules and the taxpayer’s circumstances.
  • Entity structuring (PFIC & CFC Rules): Coordinating specialist advice on local Greek corporate vehicles, holding entities and real estate SPVs, taking into account Passive Foreign Investment Company (PFIC) and Controlled Foreign Corporation (CFC) rules 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 coordinate advice on establishing residency ties in Greece and assessing whether they have ceased to be tax residents of their former US state under the relevant state laws.
  • FATCA & FBAR compliance: Coordinating assistance with Foreign Bank Account Reporting (FBAR / FinCEN Form 114) and foreign financial disclosures (Form 8938), where applicable, through independent qualified professionals.

Thoughts from Our Team

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

Why Partner With Tsaks Consulting?

  • Coordinated legal & accounting expertise: Our independent attorney and tax accountant partners work together with our advisory team, helping minimise misalignments between your tax declarations and legal contracts.
  • Cross-border focus: We specialise in cross-border wealth migration consultancy and coordination, working with independent professionals who understand the US-Greece Double Tax Treaty (DTT).
  • No travel required in many cases: Our team can assist with coordinating real estate transfers, bank account setups and tax registrations remotely via Power of Attorney (POA), where permitted and subject to the relevant legal, banking and administrative requirements. Independent qualified professionals undertake any regulated representation.
  • 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 through our consultancy services and independent professional network.

Important Information

Tsaks Consulting Greece is a business consultancy with an office in Athens and a presence in the United States. We provide business consultancy, relocation support, administrative coordination and introductions to independent qualified professionals. We are not a law firm, accounting practice or regulated financial adviser. Legal, accounting, taxation, investment and other regulated professional services are provided by appropriately qualified independent professionals within our network. Information on this website is general in nature and does not constitute legal, tax, accounting, investment or financial advice. Greek and US tax laws, eligibility requirements and regulations may change, and individual circumstances must be assessed by qualified professionals.