Transfer of tax residence and special tax Non-dom

In the context of strengthening the conditions for economic development and the preservation of economic and social cohesion, the concept of a special tax resident was introduced into our tax law by Law 4646 / 2019. The aim of these arrangements is to implement a specific low tax rate for foreign residents, which will attract foreign investors, in order to move ahead with their tax residence in our country. The institution of “resident non-resident” (non-resident) applies to non-resident residents who, for reasons of economic interest, wish to transfer their tax domicile to Greece, thereby reducing any tax liability on foreign income. In order to implement this favorable and alternative way of taxation, certain substantive conditions expressly laid down in law should be met cumulatively. In particular, it should: (1) The taxpayer was not a tax resident in Greece in previous seven (7) from the eight (8) years before the transfer of his tax residence to Greece. 2. It must be demonstrated that it invests at least five hundred thousand (EUR 500 000) in real estate or business or securities or shares or units in legal persons or legal entities established in Greece, whether he or his relatives (i.e. his spouse and ascendants / descendants in a straight line) or through a legal person or legal entity in which he holds the majority of shares or shares. Once it is integrated into that scheme, and for a maximum duration of fifteen (15) tax years, the natural person will pay a flat-rate tax, which amounts to a hundred thousand (100,000) for each tax year, irrespective of the amount of income acquired abroad. The investment which the person concerned is required to undertake should be completed within three (3) years from the date of submission of the application. The application for the transfer of the tax residence by virtue of the alternative method of taxation of income arising abroad under Law No 4646 / 2019 shall be submitted to the Tax Administration by the natural person by 31 March of the tax year in question. Accordingly, the competent department of the Administration (Tax Office of Foreign and Alternative Taxation of Taxes) is required to answer the question in question within sixty (60) days after its deposit. If the application is accepted, as a special tax resident is now subject to the same tax regime as Greek citizens, it must pay an annual flat-rate tax of EUR 100 000 (€100,000). This payment results in an exhaustion of the tax liability for all foreign income irrespective of the amount of income acquired, and a tax exemption from inheritance taxes and gifts for property abroad. In effect, it is taxed on income acquired in the Greek State, whereas it is sufficient for foreign income to pay the sum of EUR 100,000 which leads to its tax exemption. It should be noted that for the first year of entry into the provisions of that law, the natural person must reimburse the flat-rate tax within 30 (30) days of the approval of his application. In the event of non-payment of the full amount of the flat-rate tax or non-completion of the investment, the special scheme and the person in question shall be taxed on its global income on the basis of the general provisions from the tax year concerned. Notes that the flat-rate tax already paid is not returned. Furthermore, the natural person has the possibility of requesting an extension of that arrangement and for dependent members of his family by paying an additional amount of EUR 20 000. That tax shall be paid each tax year at one instalment and the adjustment shall expire at the end of fifteen (15) years without the possibility of an extension.

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