Buying Property in Greece via a Company or Trust: Strategic Approaches for International Investors
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Table of Contents
- Introduction: The Greek Property Investment Landscape
- Corporate Property Acquisition in Greece
- Trust Structures for Greek Property Ownership
- Tax Implications of Different Ownership Structures
- Real-World Applications: Case Studies
- Greek Golden Visa Program Considerations
- Legal Compliance and Regulatory Framework
- Your Strategic Roadmap: Selecting the Optimal Structure
- Frequently Asked Questions
Introduction: The Greek Property Investment Landscape
Contemplating a property investment in Greece? You’re entering a market rich with opportunity but layered with complex structural considerations. The decision between direct personal ownership, corporate acquisition, or trust structures can significantly impact your investment’s profitability, tax efficiency, and long-term security.
Greece’s property market has experienced remarkable resilience despite global economic fluctuations. With prices still below pre-2008 levels in many regions and a surging interest from international investors, the timing for strategic entry is compelling. The country offers diverse investment opportunities from Athens metropolitan apartments yielding 4-7% annual returns to luxury properties on islands like Mykonos commanding premium values.
However, the how of purchasing can be as crucial as the what. Let’s break down the maze of ownership structures available to international investors looking at property for sale in Greece, examining the strategic advantages and potential pitfalls of each approach.
Corporate Property Acquisition in Greece
Purchasing Greek property through a company structure offers distinct advantages that extend beyond traditional direct ownership. However, the benefits vary significantly depending on whether you choose a domestic or foreign corporate entity.
Using a Greek Company
Establishing a Greek company—typically a Private Capital Company (IKE) or Limited Liability Company (EPE)—for property acquisition presents several strategic advantages:
- Liability Limitation: Your personal assets remain protected, with liability generally restricted to the company’s capital
- Operational Flexibility: Simplifies property management, especially when multiple owners are involved
- Succession Planning: Ownership transfer occurs through company shares rather than complex property title transfers
- Commercial Utilization: Facilitates business operations if the property will generate rental income or serve commercial purposes
Eleftheria Kourtali, a real estate attorney based in Athens, notes: “For properties intended as vacation rentals or commercial ventures, Greek corporate structures offer streamlined operational frameworks while providing substantial protection from personal liability—a critical consideration in today’s litigious environment.“
However, this approach isn’t without challenges. Greek companies face corporate income tax rates of 22% and must navigate complex accounting requirements and annual filing obligations. Additionally, dividend distributions attract withholding tax, creating potential double taxation scenarios without proper planning.
Using a Foreign Company
Alternatively, acquiring Greek property through a foreign corporate entity—particularly from jurisdictions with favorable tax treaties—can yield significant advantages:
- Privacy Enhancement: Greater confidentiality regarding beneficial ownership in certain jurisdictions
- Tax Optimization: Potential reduced withholding taxes on dividends and capital gains through treaty networks
- Asset Protection: Additional layers of legal separation between personal wealth and property assets
- Estate Planning: Simplified inheritance processes avoiding Greek succession complications
The practicalities, however, demand careful consideration. Foreign companies owning Greek property must register with tax authorities and may face increased scrutiny. Annual substance requirements in the company’s home jurisdiction can create ongoing compliance obligations and costs that outweigh tax benefits for smaller investments.
Trust Structures for Greek Property Ownership
Trust structures represent a sophisticated alternative to corporate ownership, though they require careful navigation within Greece’s civil law framework.
Key Benefits of Trust Structures
Trust structures offer distinct advantages for certain investor profiles:
- Asset Protection: Insulation from personal creditors when properly structured
- Inheritance Planning: Circumvention of Greek forced heirship provisions for international investors
- Confidentiality: Enhanced privacy compared to direct ownership
- Flexibility: Customizable distribution mechanisms among multiple beneficiaries
Consider this scenario: An American family established an irrevocable trust in Cyprus to acquire a €1.2 million villa in Santorini. The structure allowed them to legally minimize inheritance complications across generations while creating clear management succession as elder family members aged. When one trustee passed away, property management continued seamlessly without triggering Greek inheritance procedures or taxes.
Limitations and Considerations
Trust structures aren’t universally beneficial for Greek property investment:
- Recognition Challenges: As a civil law jurisdiction, Greece doesn’t natively recognize trusts, requiring careful legal structuring
- Substance Requirements: Offshore trusts face increasing scrutiny from Greek authorities
- Administrative Complexity: Ongoing trustee responsibilities and professional fees
- Beneficial Ownership Reporting: Recent transparency regulations require disclosure of ultimate beneficial owners
Dr. Nikolaos Athanasiou, international tax specialist, cautions: “While trusts offer powerful planning tools, they’re increasingly scrutinized under OECD transparency initiatives. The structure must demonstrate genuine non-tax purposes to withstand regulatory examination. For investments below €2 million, the compliance costs often outweigh the benefits.“
Tax Implications of Different Ownership Structures
Tax considerations often drive ownership structure decisions. Let’s compare the implications across different approaches:
Tax Consideration | Direct Personal Ownership | Greek Company | Foreign Company | Trust Structure |
---|---|---|---|---|
Acquisition Taxes | 3.09% transfer tax or 24% VAT (new properties) | 3.09% transfer tax or 24% VAT (new properties) | 3.09% transfer tax or 24% VAT plus potential corporate restructuring costs | 3.09% transfer tax or 24% VAT plus trustee fees |
Annual Property Tax | ENFIA tax based on property value (0.1%-1%) | ENFIA tax plus potential supplementary tax | ENFIA tax plus special annual 15% tax unless exemptions apply | ENFIA tax plus potential additional reporting |
Income Tax (Rentals) | 15-45% progressive rates | 22% corporate rate plus dividend withholding | 22% corporate rate or treaty benefits plus dividend considerations | Depends on trust jurisdiction and beneficiary arrangements |
Capital Gains Tax | 15% with allowances for long-term ownership | 22% at corporate level | Potential exemption through treaties or offshore structures | Potentially deferred or reduced based on structure |
Inheritance/Gift Tax | 1-10% for close relatives, 20-40% for others | Share transfer potentially exempt from property transfer tax | Potentially outside Greek inheritance regime if properly structured | Often minimized through succession planning in trust deed |
This comparison reveals that optimal structuring depends on your specific circumstances—there’s no one-size-fits-all solution. An investment property generating rental income might benefit from corporate structures, while a long-term family vacation home might optimize under different arrangements.
Real-World Applications: Case Studies
Let’s examine how different investors have strategically structured their Greek property acquisitions:
Case Study 1: The Portfolio Investor
Maria, a German investor, acquired multiple apartments in Athens through a Greek IKE company. With a rental yield focus, this structure allowed her to:
- Offset property expenses against rental income
- Reinvest profits into additional properties at corporate tax rates
- Efficiently manage multiple properties under one entity
- Simplify VAT reclamation on new property purchases
The annual corporate compliance costs of approximately €3,500 were justified by the scale of her €1.2 million portfolio and operational simplicity for her property management team.
Case Study 2: The Family Estate
The Johnsons, a British family, used a Cyprus-based company to purchase a €3.5 million villa in Rhodes with complex family ownership interests. Their structure provided:
- Protection from UK inheritance tax exposure
- Simplified fractional ownership among family members
- Efficient mechanism for usage rights allocation
- Mitigation of Greek inheritance complications
Their annual maintenance costs for this structure approached €7,000—significant but warranted given the high-value asset and complex family dynamics involved.
Greek Golden Visa Program Considerations
For investors seeking residency benefits alongside property investment, Greece’s Golden Visa program offers residency permits for property investments exceeding €250,000. However, ownership structure significantly impacts eligibility:
Golden Visa Program Structure Compatibility
95%
70%
40%
25%
Percentage indicates reliability for Golden Visa qualification based on current approval patterns
Golden Visa applicants should note that while direct ownership provides the cleanest path to approval, corporate structures are possible when the applicant controls 100% of the company shares. Trust structures present significant challenges and generally require specialized legal counsel to navigate successfully.
Legal Compliance and Regulatory Framework
Greece has significantly strengthened its anti-money laundering and beneficial ownership transparency requirements in recent years. Key compliance considerations include:
- Ultimate Beneficial Owner (UBO) Registry: Companies and trusts must disclose individuals controlling more than 25% of assets
- OECD Common Reporting Standard: Automatic exchange of financial information between tax authorities
- Substance Requirements: Foreign entities must demonstrate genuine business purpose beyond tax advantages
- Annual Reporting: Regular declarations for foreign-owned properties and corporate structures
Georgios Papadopoulos, compliance officer at a leading Athens law firm, advises: “The era of opaque ownership structures has ended. Today’s successful international property investor in Greece builds compliant, transparent structures that withstand regulatory scrutiny while still optimizing legitimate tax and succession planning opportunities.“
Your Strategic Roadmap: Selecting the Optimal Structure
How do you determine which ownership structure best suits your Greek property investment? Consider this decision framework:
- Define Your Primary Objectives
- Are you prioritizing rental income, capital appreciation, or lifestyle use?
- Is residency through the Golden Visa program a key motivation?
- How important is asset protection versus operational simplicity?
- What is your investment timeframe and exit strategy?
- Assess Your Investment Scale
- For investments under €500,000, complex structures rarely justify their costs
- Multiple properties benefit from consolidated management through corporate structures
- High-value single assets (€1M+) often warrant sophisticated protection mechanisms
- Analyze Your Tax Residence Position
- How does your home country tax foreign property and corporate income?
- What tax treaties exist between your residence country and Greece?
- Would dividend repatriation trigger additional taxation?
- Consider Succession Planning
- How do Greek inheritance laws interact with your estate planning?
- Are multiple family members involved in ownership?
- What happens if a key decision-maker becomes incapacitated?
- Evaluate Ongoing Management Requirements
- Who will handle day-to-day property management?
- How will rental income be collected and distributed?
- What accounting and compliance resources are available?
Remember: The most tax-efficient structure on paper isn’t always the most practical or cost-effective in real-world application. A balanced approach considering both optimization and operational reality typically yields the best long-term results.
Pro Tip: Engage advisors with specific Greek property experience rather than general corporate structuring experts. The nuances of Greek property law, tax treatment, and banking practices demand specialized knowledge that generalists often lack.
Frequently Asked Questions
Can a foreign company purchase property in Greece without restrictions?
Yes, foreign companies can generally purchase property in Greece without restrictions, with two important exceptions. Properties in border regions and certain islands require special permissions from the Greek Ministry of Defense. Additionally, foreign companies must obtain a Greek tax registration number (AFM) and may face enhanced due diligence from Greek banks and notaries regarding source of funds and beneficial ownership. Companies from non-EU jurisdictions should verify any additional requirements based on bilateral agreements.
How does using a company for property purchase affect the Greek Golden Visa application?
Using a company structure for property acquisition can complicate Golden Visa applications but doesn’t preclude approval. The key requirement is that the applicant must own 100% of the company shares, and the investment value must clearly exceed the €250,000 threshold. Additional documentation will be required to demonstrate the ownership chain. The application process typically takes 2-3 months longer when corporate structures are involved, and authorities scrutinize these applications more rigorously to prevent program misuse.
What are the annual compliance costs for maintaining a Greek property-holding company?
Annual compliance costs for a Greek property-holding company typically range from €2,500 to €7,000 depending on complexity. This includes accounting services (€1,200-€3,000), annual corporate tax filings (€500-€1,500), legal representative fees (€500-€1,000), and statutory requirements such as shareholder meetings. Companies with rental operations face additional compliance requirements including monthly or quarterly VAT filings. Foreign companies owning Greek property must also maintain tax compliance in their home jurisdiction, potentially doubling these costs for smaller investments.
Navigating Your Greek Property Investment Journey: Action Steps
As we’ve explored, the structure through which you purchase Greek property significantly impacts your investment’s performance, protection, and long-term flexibility. While the optimal approach varies based on individual circumstances, certain principles apply universally.
Begin by assembling the right advisory team—a Greek property lawyer, a tax specialist familiar with both Greek and your home jurisdiction’s requirements, and if appropriate, a corporate services provider. These professionals should collaborate to design a structure aligned with your specific objectives rather than offering one-size-fits-all solutions.
For most individual investors purchasing a single property under €1 million for personal use, direct ownership offers the best balance of simplicity and cost-efficiency. For larger investments, commercial operations, or complex family arrangements, corporate structures provide valuable benefits that justify their additional complexity.
Perhaps most importantly, approach structuring decisions with both current circumstances and future flexibility in mind. The property you purchase as a vacation home today might become a rental investment tomorrow, or part of a larger portfolio. Building adaptability into your initial structure can save significant costs and complications later.
What property investment goals are you looking to achieve in Greece, and how might your ownership structure enhance or limit those ambitions? The answers to these questions will guide you toward not just a successful property acquisition, but a truly optimized investment strategy in one of Europe’s most promising real estate markets.
Article reviewed by Jean Dupont, Institutional Investment Advisor | ESG & Impact Investing Pioneer | Aligning Profit with Purpose for Pension Funds, on April 29, 2025