For non-residents with Greek assets, the tax picture is manageable. For those considering relocation, the opportunity is exceptional — and structuring decisions made now determine the outcome.

You own a property in Crete. Or you hold shares in a Greek company your family started twenty years ago. Or you are watching the Golden Visa programme and calculating whether Athens, Thessaloniki, or one of the islands might eventually suit a relocation. You are not a Greek tax resident. Not yet.

But you have Greek assets. And those assets create Greek tax exposure that most non-resident owners manage imperfectly — and that PPLI can help address, both now and in the context of any future move.

This article is for non-residents with existing Greek assets and for those who are considering relocation to Greece. The two groups have different priorities, but both benefit from understanding what Greece’s tax structure means for them — and what planning tools are available.

First: What Greece Taxes Non-Residents On

Non-residents are taxed in Greece only on Greek-source income and Greek-situs assets. The main exposures are:

• ENFIA (Ενιαίος Φόρος Ιδιοκτησίας Ακινήτων): Greece’s annual real estate property tax, applied to all owners of Greek property regardless of where they live. ENFIA is calculated on the zone value, type, and floor area of the property. It cannot be eliminated through PPLI — it is a real estate tax, not an income or wealth tax.
• Dividends from Greek companies: 5% withholding tax (Article 36 ITC). This is the lowest dividend tax rate in the European Union.
• Capital gains on Greek real estate: 15% (Article 42 ITC), subject to ongoing AADE guidance on the scope of the personal-use property suspension.
• Inheritance tax on Greek-situs assets: applies to Greek property and Greek-registered financial assets on death. Category A (direct heirs) allowance is €150,000 per heir, with rates of 1%–10% on the excess. Named beneficiaries of life insurance policies receive proceeds exempt from inheritance tax — a key planning tool.

What Greece does not tax non-residents on: foreign-source income, capital gains on foreign securities, PPLI policies issued outside Greece. For non-residents, the Greek tax picture is clean — it is bounded and specific.

ENFIA — Living With It, or Planning Around It

ENFIA is unavoidable for direct Greek property owners. It applies every year, to every owner, resident or not. The rates are calculated on property values, and for premium locations — Athens, Mykonos, Santorini, Thessaloniki — the annual ENFIA can be material.

Where does PPLI come in? Directly held Greek real estate cannot be placed inside a PPLI policy. But the corporate ownership of Greek property opens a different conversation. Where a non-resident holds Greek property through a corporate vehicle — a Greek AE or EPE, or a foreign company with Greek property — the shares in that company are financial assets that can, in principle, be held within a PPLI policy. The succession planning on those shares then benefits from the Greek life insurance inheritance-tax exemption.

This structure is complex and requires specialist Greek real estate, corporate, and insurance law advice. It is not a simple plug-and-play solution. But for significant Greek property holdings where succession across generations is a concern, the ability to wrap the corporate shares inside PPLI and name beneficiaries who will receive those shares free of Greek inheritance tax is a genuine planning option.

The Succession Question — Greek Assets, Cross-Border Families

The single most underappreciated feature of Greek tax law for non-residents is the inheritance tax exemption on life insurance proceeds. When a Greek-law-compliant life insurance policy — including a properly structured PPLI policy issued from Luxembourg or Liechtenstein — pays out to named beneficiaries on the policyholder’s death, those proceeds are exempt from Greek inheritance tax.

This applies regardless of whether the beneficiaries are Category A (direct family), Category B (siblings, wider family), or Category C (unrelated persons). The exemption cuts across all categories. A non-resident policyholder who owns Greek financial assets — Greek fund units, shares in Greek companies, Greek bank deposits — and who wraps those assets within a PPLI policy can use this exemption to pass those assets to any named beneficiary free of Greek inheritance tax.

Compare: Greek real estate held directly passes under Category A at 1%–10% (which is very low — but it still passes through the estate, through Greek probate, and through AADE). The PPLI route bypasses the estate entirely for the financial assets. The death benefit flows directly. For cross-border families where the policyholder is French, British, or Russian and the beneficiaries are in multiple countries, this is a structurally cleaner solution than direct estate succession.

The Greek life insurance inheritance-tax exemption does not ask who the beneficiary is or what their relationship to the policyholder is. It asks only whether the proceeds are paid to a named beneficiary under a genuine life insurance contract. If yes, they are exempt. Full stop.

The Forward-Looking Angle — Greece Is the Best Destination in the EU for PPLI

Now for the larger picture. If you are reading this as a non-resident who holds Greek assets and who is considering, at some future point, transferring residency to Greece — you should be planning that move in detail. Because the tax outcome of relocating to Greece, in combination with PPLI, is not matched anywhere else in the European Union.

For any portfolio generating more than approximately €333,000 per year in investment returns, Greece’s Article 5A is cheaper than France’s 30% standard rate and cheaper than Italy’s new €200,000 flat tax. The 7% Article 5B rate for qualifying retirees is the lowest effective rate on PPLI gains available in any EU member state, full stop.

The Pre-Residency Conversation — Timing Is Everything

If you hold large unrealised gains in foreign equities, alternative assets, or cryptocurrency — and you are planning a move to Greece — the single most valuable planning conversation you can have is about timing.

The sequence that produces the best outcome:

• Establish the PPLI policy while still resident in your current jurisdiction.
• Transfer the investment portfolio into the policy — wrapping existing unrealised gains inside the wrapper before Greek tax jurisdiction attaches.
• Make the qualifying investment in Greece (€500,000 for Article 5A; the Golden Visa property purchase can satisfy both requirements simultaneously).
• Transfer Greek tax residence and file the Article 5A or 5B application by 31 March of the first year.

From the moment Greek residency begins, all subsequent gains inside the policy accumulate tax-deferred, with the surrender gain covered by the flat annual payment or 7% rate. The gains that accrued before Greek residency were wrapped before the Greek tax net applied — they are inside the policy, deferred, waiting for a surrender that will cost €100,000 in tax, regardless of how large they are.

Why Non-Residents Are Ideal PPLI Clients Right Now

There is a particular planning urgency for non-residents who hold Greek assets and who are considering relocation. The Article 5A and 5B regimes both have a 15-year clock. Every year of residency without the structure in place is a year of the clock consumed without the pre-residency PPLI benefit.

The regime is available today. The planning tools are established and understood. The PPLI carriers in Luxembourg and Liechtenstein are experienced with Greek-resident policyholders. The Golden Visa programme is running. The comparison with Italy, Spain, and France is favourable and becoming more so as those jurisdictions increase their tax burdens.

Greece has been underwritten by the wealth management community as a PPLI destination. That is beginning to change. The clients who move through the pre-residency planning sequence now — before the regime becomes more widely understood — are the ones who benefit most from the 15-year window.

A Note on the Greek Property in Your Estate

For non-residents who will not relocate to Greece but who hold Greek property or other Greek assets, the planning takeaway is more modest but still valuable. The life insurance exemption means that any liquid Greek financial assets — bank deposits, Greek fund units, shares in Greek entities — can be structured inside a PPLI policy with named beneficiaries, achieving inheritance-tax-free succession on those specific assets.

The Greek real estate in the estate passes through standard succession. For Category A heirs, the rates and allowances are genuinely generous by EU standards (€150,000 per heir; 1%–10% on the excess). For others, a corporate structure analysis is worth pursuing.

The PPLI is not a solution to ENFIA — that is a property tax and will always apply. But it can be a solution to succession complexity on the liquid Greek assets — and that is a meaningful contribution to any cross-border estate plan involving Greece.