Greece

Tax residency

Under Article 4 of the Greek Income Tax Code (Law 4172/2013), an individual is a Greek tax resident if they satisfy any applicable domestic tax-residency criterion. The rules were clarified by AADE Circular E.2064/2023, which states that the criteria follow the terminology and framework of the OECD Model Tax Convention.

Thus, Greek domestic tax residence may arise under any applicable Article 4 criterion. The first four criteria are factual residence or personal/economic connection criteria, while the 183-day rule is a separate physical-presence criterion.

• Permanent residence (μόνιμη κατοικία): This refers to a residence in Greece that is continuously available to the individual and used on a permanent rather than occasional basis. The individual must have the residence in their possession or at their disposal at any time and continuously. A residence is not considered available to the individual while it is rented to another person. Permanence depends on whether the individual has organised and maintains the residence in a condition that permits permanent use, rather than use for a short-term or occasional purpose such as a holiday, business trip or study trip.
• Principal residence (κύρια κατοικία): This distinguishes the individual’s main residence from a secondary residence. An individual may be a Greek tax resident where their principal residence, in which they are actually established, is in Greece even if they also have one or more secondary residences abroad. A qualifying residence may be a house, apartment, rented furnished room or other accommodation that can be used as a dwelling, whether owned, rented or provided free of charge.
• Habitual abode (συνήθης διαμονή): This refers to the place where the individual is systematically or usually present. It is not determined by a specific number of days. Instead, the assessment considers the frequency, duration and regularity of the individual’s stays as part of their established pattern of life, rather than stays arising from exceptional, extraordinary or transitional circumstances. All relevant stays in Greece are considered, including stays in different locations and successive hotel stays.
• Centre of vital interests (κέντρο των ζωτικών συμφερόντων): This is the centre of the individual’s personal and economic relations. Personal ties may include the location of family members, wider family relationships, social relationships and activities, relationships with public and other institutions, and cultural or other activities. Economic ties include professional activities and the place from which the individual manages their assets. The various personal and economic factors must be considered together, on an ad hoc basis and as a whole. Holding of a position in a Greek company or the carrying out of a single activity in Greece is not, by itself, sufficient where the individual demonstrates that their life has been organised on a permanent and lasting basis abroad.
• 183-day physical presence: An individual who is present in Greece for more than 183 days, cumulatively, during any 12-month period is considered a Greek tax resident from the first day of their presence in Greece. The test is subject to the statutory exception for individuals present in Greece exclusively for touristic, medical, therapeutic or similar private purposes where the stay does not exceed 365 days, including short periods spent abroad.

Day counting

• Permanent residence (μόνιμη κατοικία): no fixed physical-presence threshold applies. The relevant issue is whether the residence is continuously available to the individual and maintained for permanent rather than occasional use. For example, a property owned by the individual but rented to another person is not treated as available to the owner during the rental period.
• Principal residence (κύρια κατοικία): no fixed day-count threshold applies. The assessment concerns whether the individual is actually established in Greece in their principal residence, as distinct from any secondary residences.
• Habitual abode (συνήθης διαμονή): no specific number of days is prescribed. The assessment considers the frequency, duration and regularity of stays as part of the individual’s established pattern of life. Stays in different places in Greece, including successive hotel stays, may be taken into account.
• Centre of vital interests (κέντρο των ζωτικών συμφερόντων): no fixed day-count threshold applies. The relevant personal and economic ties are assessed together and on a case-by-case basis.
• 183-day physical presence: the test is cumulative and applies over any 12-month period. Any day during which an individual is physically present in Greece counts as a day of presence, however short the presence may be, including a part of a day, the day of arrival, the day of departure, holidays, public holidays and similar days.
• Touristic / medical / similar private stays: where the statutory exception applies, periods attributable to these purposes are excluded from the 183-day calculation. If, after excluding those periods, the remaining presence exceeds 183 days, the individual becomes a Greek tax resident under the 183-day rule. If such a stay exceeds 365 days, including short periods abroad, the individual is treated as resident from the first day of presence.

Tax consequences

The Greek tax year is a calendar year. Greek tax residents are generally subject to tax on worldwide income, while non-residents are generally subject to Greek tax on Greek-source income, subject to applicable treaty provisions.

Migration / EU residence

EU/EEA citizens may reside in Greece under the applicable free-movement rules, while Swiss citizens are subject to the applicable Swiss-specific residence arrangements. Third-country nationals may stay in Greece for short stays of up to 90 days in any 180-day period, subject to applicable visa requirements. Stays exceeding 90 days generally require a long-stay visa or residence authorisation. Immigration residence status does not, by itself, determine Greek tax residency.

Orientation references

• Greek Income Tax Code (Law 4172/2013), Article 4
• Independent Authority for Public Revenue (AADE), Circular E.2064/2023, Interpretation and application of Article 4
• Greek immigration / EU residence framework