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For an Australian who owns an international or online business and is genuinely willing to relocate, Greece offers one of the most efficient personal tax outcomes available anywhere in the European Union. This is a relocation strategy, not a paper structure. It depends on actually moving to Greece and making it your home. For those who do, the reward is significant: a Greek tax resident pays a flat 5 per cent tax on dividend income. Not 5 per cent up to a threshold, and not 5 per cent after deductions. For an individual, that single 5 per cent payment discharges the entire Greek tax liability on the dividend.
This guide sets out how the strategy works, who it works for, how an Australian relocating to Greece becomes a Greek tax resident (whether through an EU passport or the Golden Visa), and the issues that have to be managed to make it hold up.
The strategy in one paragraph
An international corporate structure is established in a tax-efficient jurisdiction. The company earns and accumulates business or investment income. It then pays dividends to its shareholder, who is a Greek tax resident individual. Greece taxes that dividend at 5 per cent. If the company sits in a jurisdiction that does not impose dividend withholding tax, 5 per cent is the total tax cost of moving the money into the shareholder's hands.
Who the strategy works for
The strategy works for businesses whose income is genuinely international or location-independent, rather than tied to an Australian premises or an Australian customer base. In practice that means technology and software businesses, content creators and influencers, online service, marketing and consulting businesses, intellectual property holding, and investment portfolios held through a company.
What these have in common is that the income can legitimately be earned and accumulated through a company outside Australia, and the owner can run that business from anywhere. A bricks-and-mortar Australian business does not fit, because its income remains Australian-sourced and Australian-taxed regardless of where the owner lives. An online or international business does fit, which is what makes the relocation worth doing.
The 5 per cent dividend tax
Greek tax residents are taxed on their worldwide income. Dividends, whether Greek-source or foreign-source, are taxed at a flat 5 per cent. For an individual, the 5 per cent is a final tax on that income. There are no progressive rates applied to it and no further layer of tax. Dividends are passive income and are not subject to Greek social security contributions.
The contrast with Australia is stark. An Australian resident pays tax on dividends at marginal rates up to 47 per cent. Even fully franked dividends only reduce that burden, they do not remove it, and unfranked or foreign dividends carry the full marginal rate. For a business owner whose income is largely paid out as dividends, the move from up to 47 per cent to a flat 5 per cent is the entire point of the exercise.
Greece also offers several special tax regimes (a lump-sum regime for high-net-worth individuals, a 7 per cent regime for foreign pensioners, and a 50 per cent exemption for relocating workers). For income that is predominantly dividends, the ordinary 5 per cent treatment is usually the simplest and the cheapest, which is why it is the focus of this guide.
Becoming a Greek tax resident
The 5 per cent rate is a benefit of being a Greek tax resident, so the relocation has to be real. An individual becomes a Greek tax resident if either they are physically present in Greece for more than 183 days in any 12-month period, or Greece is their centre of vital interests, meaning their principal home, family, and economic and social ties are located in Greece.
A Greek tax resident is taxed on worldwide income. A non-resident is taxed only on Greek-source income. Becoming a resident is therefore a deliberate step, and it is the step that unlocks the dividend treatment.
Route 1: an EU passport
The simplest way into Greece is an EU passport, because EU citizenship carries freedom of movement. An EU citizen can move to Greece, or to any other member state, and live there indefinitely with no visa, no investment and no permit. The relocation becomes a purely practical exercise.
A surprising number of Australians are eligible for an EU passport without having pursued it. Australia's post-war migration means many Australians have Italian, Greek, Maltese, or other European parents or grandparents, and several EU member states grant citizenship by descent across one or more generations. An Australian who already holds, or can establish eligibility for, any EU passport has the cleanest route into the strategy. The Greek passport is only one of many that work; the relevant question is EU citizenship, not Greek citizenship specifically. Citizenship by descent involves an administrative process and can take time, so it is worth assessing eligibility and starting early.
Route 2: the Greek Golden Visa
For Australians without an EU passport, the Golden Visa is the residence-by-investment route into Greece. It grants a five-year renewable residence permit that covers the investor, their spouse and their dependent children, and allows visa-free travel throughout the Schengen Area. Processing currently takes approximately six to nine months.
The 2026 investment thresholds are tiered by location:
- EUR 800,000 for real estate in Attica (including all of Athens and the Athens Riviera), greater Thessaloniki, Mykonos, Santorini, and islands with a population above 3,100. The investment must be a single property of at least 120 square metres.
- EUR 400,000 for real estate anywhere else in Greece, again a single property of at least 120 square metres.
- EUR 250,000 for a property converted from commercial to residential use, or for the restoration of a listed building, available anywhere in the country.
- Alternative routes include a EUR 500,000 fixed-term deposit with a Greek bank, a EUR 500,000 capital contribution to a Greek real estate investment company, and a 10-year lease of hotel accommodation or furnished tourist residences.
One restriction matters for investors who think of property as a yield asset: Golden Visa real estate cannot be placed into short-term (Airbnb-style) letting. Breach triggers revocation of the permit and a EUR 50,000 fine.
The most important point about the Golden Visa is also the most commonly misunderstood. The Golden Visa gives the holder the right to reside in Greece. It does not, by itself, make the holder a Greek tax resident, and it does not require the holder to live in Greece at all. To obtain the 5 per cent dividend treatment, the holder must separately and genuinely become a Greek tax resident under the 183-day or centre-of-vital-interests test described above. Treat the Golden Visa as the immigration key, and tax residency as a separate, deliberate decision.
The corporate structure
The other half of the strategy is where the company sits. The company should be established in a jurisdiction that taxes the relevant income lightly or not at all, and that does not impose a dividend withholding tax on distributions to a Greek-resident individual.
Where a source jurisdiction does withhold tax on the dividend, Greece generally allows a credit for that foreign tax against the 5 per cent. A jurisdiction with no dividend withholding tax means there is nothing to credit and the 5 per cent is the entire cost. The choice of jurisdiction, the substance the company carries, and the way it is managed all need to be designed together.
There is no single correct jurisdiction. The right choice depends on the nature of the business, the income mix, the substance the client can genuinely establish, and the client's broader circumstances. Our other articles discuss the various corporate jurisdictions in detail, and Cadena International advises on the best choice for each client's situation.
The issues that have to be managed
The strategy is sound, but it depends on four things being handled properly.
1. Greek controlled foreign company rules
Greece can attribute the undistributed passive income of a foreign company directly to a Greek-resident shareholder where the shareholder controls more than 50 per cent of the company, the foreign tax paid is less than half the tax that would be paid in Greece, and more than 30 per cent of the company's income is passive. There are two answers to this. The first is that the strategy distributes dividends, and the controlled foreign company rules bite on income that is not distributed, so a genuine distribution policy reduces the exposure. The second is that a company established in an EU jurisdiction and carrying on genuine economic activity falls outside the rules. The structure should be designed with this in mind from the outset.
2. Place of effective management
If the shareholder runs the foreign company day-to-day from Greece, Greece can treat the company itself as a Greek tax resident, on the basis that it is managed and controlled from Greece. That would expose the company's entire profit to Greek corporate tax of 22 per cent before the dividend question is even reached. The company needs genuine management substance outside Greece.
3. Ceasing Australian tax residency
The 5 per cent rate is only meaningful once the shareholder is no longer an Australian tax resident. While they remain an Australian resident, Australia taxes the same dividends at up to 47 per cent. The departure from Australian residency must be clean and deliberate, and it must account for CGT event I1, which deems a disposal of the departing resident's non-Australian-property assets at market value on the day they cease to be a resident. This is a consequence to plan for, not to discover after the fact.
4. No Australia-Greece tax treaty yet
Australia and Greece reached in-principle agreement on a double tax treaty in March 2026, but it has not been signed and is not yet law. Until it is, the position on both sides is governed purely by domestic law. That makes a clean break from Australian tax residency more important, because there is no treaty tie-breaker to fall back on, and it makes the choice of a zero-withholding corporate jurisdiction more important, because there is no treaty rate to rely on.
Is Greece the right destination?
Greece suits owners of international or online businesses (technology, content creation and influencer businesses, online services, IP and investment holding) whose income is largely paid as dividends, Australians who hold or can obtain an EU passport, and people who are genuinely willing to make Greece their home. It is less suited to those who cannot or will not actually relocate, those whose business income remains Australian-sourced, and those whose income is mainly personal services income, which is taxed in Greece at progressive rates up to 44 per cent rather than at 5 per cent.
For the right person, the combination is rare: a Mediterranean home in the European Union, freedom of movement, and a 5 per cent tax on the income that funds the lifestyle. The strategy rewards being deliberate. The relocation has to be real, the Australian exit has to be clean, and the corporate structure has to be built with the Greek rules in mind.
Cadena International advises Australians on international relocation and corporate structuring, including the Greek strategy described here. If you are considering a move to Greece, we can help you design and implement it. You may also be interested in our guides to relocating to Panama and the Cayman Islands.
This material is produced by Cadena International. It is intended to provide general information and opinions on legal topics, current at the time of first publication. The contents do not constitute legal advice and should not be relied upon as such.
