Relocating fund management to Greece under Law 5313/2026

Law 5313/2026 was published in the Greek Government Gazette on 25 June 2026 and applies from 1 January 2026. It confirms that EU alternative investment funds, and qualifying funds from non-EU countries supervised by an IOSCO-member authority, are not taxed in Greece; it provides that managing, advising or providing support services to such funds from a Greek company does not by itself create Greek tax residence or a permanent establishment for the fund, its investment vehicles, its manager or its investors; and it extends Greece's carried-interest regime to contractual performance remuneration paid to employees of Greek companies that provide services to an affiliated fund manager.

Contractual performance remuneration paid by a Greek company to its employees is taxed as a capital gain at 15% rather than as salary, provided the company provides services to a qualifying fund manager. The rate falls to 5% where the employee has moved to Greece under the Article 5C inbound-employee regime and the Greek company spends at least €3 million a year in Greece. The 5% rate applies for seven tax years from the year of the Article 5C application and cannot be extended. Remuneration relating to periods before the move to Greece and before the Greek employment began is not subject to Greek tax.

Article 5C of the Greek Income Tax Code is the regime for employees who move their tax residence to Greece to take up employment with a Greek company. Broadly, the individual must not have been Greek tax resident for five of the previous six years, must move from an EU or EEA country or a country with a tax-cooperation agreement with Greece, and must intend to stay at least two years. Half of the individual's Greek employment income is exempt from income tax for seven years. Under Law 5313/2026, Article 5C status is also the condition for the 5% rate on performance remuneration.

Article 5A is Greece's regime for individuals who move their tax residence to Greece and pay a flat €100,000 a year, which covers all income and gains arising outside Greece regardless of amount, with a further €20,000 a year for each family member included. Foreign tax paid on that income is not credited against the flat charge, and foreign-source income need not be declared in detail. The individual must not have been Greek tax resident for seven of the previous eight years and must invest at least €500,000 in Greek real estate, businesses or securities within three years; this requirement is treated as met for holders of an investment-based residence permit. The regime lasts up to fifteen years, and assets situated outside Greece are outside Greek gift and inheritance tax. Since Law 5313/2026 the fixed 31 March application deadline has been removed and the annual charge is payable by the last working day of December.

Yes. The provision that previously prevented an Article 5C employee from also electing Article 5A was repealed with effect from 28 July 2025, so the two regimes can be held in parallel: Article 5C covers Greek employment income and unlocks the 5% rate on performance remuneration, while Article 5A covers income and gains arising outside Greece. The order and timing of the two applications should be confirmed by counsel for each individual.

For the 5% rate to apply, the Greek company employing the individual must incur at least €3 million of annual operating expenses in Greece. Where the obligation covers less than a full tax year the minimum is reduced proportionately. The expense base must be evidenced to the Greek tax authority, so it is treated as a design constraint when the Greek operation is planned, not as an afterthought.

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