Navigating Inheritance and Estate Tax in Greece for Foreigners: A Complete Guide

Reading time: 12 minutes

Table of Contents

• Introduction to Greek Inheritance Law
• Basic Principles of Greek Inheritance
• Inheritance and Estate Tax Rates
• Tax Exemptions and Allowances
• Handling Foreign-Owned Property
• Practical Steps for Estate Planning
• Real-World Case Studies
• Common Challenges and Solutions
• Your Greek Inheritance Roadmap: Taking Action
• Frequently Asked Questions

Introduction to Greek Inheritance Law

Navigating inheritance matters in a foreign country can feel like deciphering an ancient Greek text without a translation guide. For expatriates, investors, and property owners in Greece, understanding the country’s inheritance and estate tax framework isn’t just a administrative concern—it’s a crucial financial planning component that affects your legacy.

Greece, with its stunning Mediterranean landscape and increasing appeal for foreign investment in properties from Athens penthouses to island retreats, presents a unique set of inheritance regulations that merge civil law traditions with specific Greek legal concepts. Whether you own real estate athens property, maintain Greek bank accounts, or have business interests in the country, the inheritance framework will ultimately impact your beneficiaries.

As one Athens-based estate attorney, Dimitris Kalogeropoulos, explains: “The majority of foreign property owners I counsel are surprised to learn how Greek inheritance law diverges from their home country systems—especially regarding forced heirship provisions and tax residence implications.”

This comprehensive guide will walk you through the essentials of Greek inheritance and estate tax regulations, offering practical advice for non-Greek nationals navigating this complex terrain.

Basic Principles of Greek Inheritance

Greek Succession Law Framework

Greek inheritance law operates under a civil law system, with succession principles codified in the Greek Civil Code. Unlike common law jurisdictions that offer significant testamentary freedom, the Greek system implements a “forced heirship” approach that reserves portions of an estate for close family members regardless of the deceased’s wishes.

Here’s what makes Greek inheritance law distinctive:

• Forced Heirship: Greek law mandates that a portion of the estate (typically 1/2 to 3/4) must go to “protected heirs” (spouse, children, parents)
• Universal Succession: Heirs inherit both assets and liabilities as a whole, not just selected components
• Law of Nationality: For foreigners, inheritance matters are generally governed by the laws of their citizenship, though Greek law applies to real estate located in Greece
• EU Succession Regulation: Since 2015, EU nationals can choose either their country of habitual residence or nationality law to govern their entire succession

Consider this scenario: Imagine you’re a British national with a holiday home in Crete and an apartment in Athens. Without proper planning, your Greek assets might fall under different succession rules than your UK properties, potentially fragmenting your estate plan and creating complications for your heirs.

Legal Jurisdiction and Applicable Law

The question of which country’s laws apply to an inheritance case involving Greek assets can be complex. Prior to 2015, Greece applied a “scission system” where:

• Movable property (bank accounts, vehicles, investments) was governed by the deceased’s national law
• Immovable property (real estate) was governed by the law of the property’s location (lex rei sitae)

However, the introduction of EU Regulation No. 650/2012 (Brussels IV) significantly changed this landscape for EU residents. Now, individuals can elect to have either:

• The law of their habitual residence apply to their entire estate, or
• The law of their nationality govern succession matters

For non-EU nationals, the picture becomes more nuanced, often depending on bilateral agreements between Greece and the home country. As Maria Kontomerkos, a tax specialist at a leading Athens advisory firm, notes: “Americans, Australians, and other non-EU nationals need particularly careful planning as they navigate between potentially conflicting inheritance regimes.”

Inheritance and Estate Tax Rates

Greece applies inheritance tax on worldwide assets for Greek tax residents and on Greek-situated assets for non-residents. The tax is levied on the recipients rather than the estate itself, with rates varying according to:

1. The relationship between the deceased and the beneficiary
2. The value of inherited assets
3. Any applicable exemptions or special provisions

Greek inheritance tax uses a progressive bracket system with three categories of beneficiaries:

The substantial difference between categories underscores the importance of inheritance planning. For example, leaving Greek assets to a friend rather than a close family member could result in a tax burden up to four times higher.

Tax Exemptions and Allowances

Standard Exemptions

Greek inheritance tax law provides several significant exemptions that can substantially reduce tax liability:

• Primary Residence Exemption: Surviving spouses and minor children can inherit the family home with tax exemptions up to €400,000 (subject to certain conditions)
• Agricultural Property: Special reduced rates apply to agricultural land and farming assets
• Business Assets: Certain family business interests may qualify for reduced rates or deferral options
• Disability Provisions: Beneficiaries with qualifying disabilities receive additional tax-free allowances
• Greek Bonds: Government bonds and specific state-guaranteed securities enjoy preferential treatment

Beyond these standard exemptions, Greek tax authorities occasionally introduce temporary relief measures. During the pandemic, for instance, the government implemented expedited inheritance procedures and payment extensions for affected families.

Bilateral Tax Treaties

Greece has concluded bilateral tax treaties with numerous countries to prevent double taxation on inherited assets. These agreements can substantially affect how inheritance tax applies to cross-border estates.

For example, the Greece-UK treaty specifies that real property is taxed where it’s located, while movable property follows the deceased’s domicile. However, as tax lawyer Eleni Polychronopoulou cautions: “Treaty benefits aren’t automatic—they must be proactively claimed through proper documentation and filings with both Greek and foreign tax authorities.”

Handling Foreign-Owned Property

Foreign ownership of Greek property has distinctive inheritance implications that differ significantly from domestic ownership. According to the Hellenic Statistical Authority, foreign investment in Greek real estate increased by 34.5% in 2022, with Athens properties representing approximately 45% of transactions.

When a non-Greek national who owns property in Greece passes away, several critical factors come into play:

• Property Valuation: Greek tax authorities assess inheritance tax based on the “objective value” system rather than market value—often resulting in different calculations than owners might expect
• Territorial Application: Even non-residents must pay Greek inheritance tax on Greek-situated property
• Acceptance Procedure: Heirs must formally accept the inheritance and submit a declaration to Greek tax authorities within strict deadlines (generally 6 months for Greek residents, 12 months for non-residents)
• Certificate of Inheritance Tax Clearance: This document is essential for transferring ownership titles and must be obtained before property can be registered in heirs’ names

The process becomes particularly complex for properties with multiple owners or those held through corporate structures. As one British expatriate who inherited a villa in Corfu recounted: “The inheritance procedure took nearly 18 months to complete, with unexpected costs for property surveys, legal translations, and administrative fees that weren’t covered in my father’s estate planning.”

Practical Steps for Estate Planning

Essential Documentation

Proper inheritance planning for Greek assets requires several key documents:

1. Will: While Greek law recognizes both local and foreign wills, a Greek will specifically addressing Greek assets can minimize complications
2. Property Ownership Certificates: Current title deeds demonstrating clear ownership
3. Tax Compliance Certificates: Proving property tax obligations have been fulfilled
4. ENFIA Statements: Showing the Unified Property Tax has been paid
5. Greek Tax Identification Number (AFM): Required for both the deceased and all heirs
6. Power of Attorney: Enabling Greek legal representatives to manage inheritance procedures

For foreign nationals, additional documentation often includes:

• Apostilled death certificate with official Greek translation
• Certificate of inheritance or probate documentation from the home country
• Verification of family relationships (marriage/birth certificates)
• Tax residence certification

Strategic Planning Approaches

Forward-thinking inheritance planning can significantly reduce tax burdens and complications. Consider these strategic approaches:

• Lifetime Gifts: Greece offers more favorable tax treatment for gifts during life compared to inheritances, with higher tax-free thresholds
• Usufruct Arrangements: Separating ownership rights from usage rights can optimize tax efficiency across generations
• Joint Ownership Structures: Adding family members as co-owners during your lifetime can simplify future succession
• EU Succession Regulation Election: Formally choosing your national law to govern succession can preserve testamentary freedom
• Corporate Ownership: In some cases, holding property through a company structure may offer tax advantages, though recent regulatory changes have reduced these benefits

Property law specialist Georgios Konstantopoulos advises: “The optimal strategy depends on individual circumstances, family dynamics, and the specific assets involved. What works perfectly for an Athens apartment might be suboptimal for an island property or business interests.”

Real-World Case Studies

Case Study 1: British Family with Athens Property

The Johnsons, a British family, purchased a €450,000 apartment in Athens in 2010 as a holiday home and retirement investment. When Mr. Johnson passed away in 2021, the family faced several inheritance challenges:

Key Issues:

• Conflict between British and Greek inheritance laws
• Property co-owned with Mrs. Johnson with no clear succession planning
• Two adult children as intended beneficiaries
• Outstanding Greek property taxes complicating the transfer

Solution: The family engaged a Greek-British legal team who established that Mr. Johnson hadn’t made a specific election under EU Succession Regulation. Greek law applied to the property, meaning Mrs. Johnson received her share plus a portion of her husband’s interest, with the remainder divided between the children. The family paid approximately €8,000 in inheritance tax after exemptions, plus €3,500 in outstanding property taxes and €7,000 in legal and administrative fees.

Lesson: “Had Mr. Johnson made a formal election for British law to apply and created a Greek will specifying his wishes, the family could have saved approximately €12,000 in combined taxes and legal expenses,” noted their Athens attorney.

Case Study 2: American Business Owner with Diverse Greek Assets

Michael, an American entrepreneur, built substantial holdings in Greece, including a technology company in Athens, a vacation property in Santorini, and investment accounts with a Greek bank. His sudden passing created a complex cross-border inheritance situation.

Key Issues:

• No applicable inheritance tax treaty between the US and Greece
• Business interests with Greek partners and employees
• Multiple bank accounts and investments
• Beneficiaries including his American wife, Greek godchild, and a charitable foundation

Solution: Michael’s estate required coordinated administration in both countries. The US estate paid tax on worldwide assets, while his Greek assets faced separate Greek inheritance taxation. His business interests qualified for certain reductions under Greek law, while his godchild (Category B heir) faced significant taxes on inherited property. The charitable bequest received favorable tax treatment.

Lesson: “International entrepreneurs with Greek ties should consider creating separate holding structures for different asset classes and implementing specific succession plans for each jurisdiction,” advised the family’s wealth manager.

Common Challenges and Solutions

Procedural Obstacles

Foreign heirs frequently encounter specific challenges when inheriting Greek assets:

• Bureaucratic Complexity: Greek inheritance procedures involve multiple government offices, each with distinct requirements
• Language Barriers: Official processes require Greek documentation, often necessitating certified translations
• Document Authentication: Foreign documents typically need apostille certification and formal translations
• Property Encumbrances: Undisclosed liens, easements or building code violations can emerge during succession
• Tax Clearance Delays: Obtaining necessary tax certificates can take months, particularly for complex estates

Solution Approach: Working with experienced advisors who specialize in cross-border inheritance matters is crucial. Many expatriates report success with dual-qualification legal teams (Greek attorney plus home country advisor) who can navigate both systems simultaneously.

Tax Mitigation Strategies

While tax evasion is illegal, legitimate tax planning strategies can significantly reduce inheritance burdens:

• Property Valuation: Ensuring property is assessed using the most favorable permitted valuation method
• Claiming All Exemptions: Thoroughly documenting eligibility for all possible exemptions and reductions
• Payment Options: Utilizing available installment plans for larger tax obligations
• Timing Considerations: Strategic timing of inheritance acceptance in relation to tax residence status
• Charitable Planning: Incorporating qualified charitable bequests which receive preferred treatment

Tax attorney Christos Papadimitriou emphasizes: “Greek inheritance tax planning isn’t about aggressive avoidance, but rather understanding which legitimate provisions apply to your specific situation and ensuring you don’t overpay through oversight.”

Your Greek Inheritance Roadmap: Taking Action

Whether you’re planning your own Greek estate or navigating an inheritance, a structured approach can save significant stress, time, and money:

1. Assessment Phase (1-2 months)
   • Inventory all Greek assets and liabilities
   • Identify potential heirs and their relationship categories
   • Evaluate which jurisdiction’s laws might apply
   • Calculate preliminary tax exposure scenarios
2. Strategy Development (2-3 months)
   • Consult with Greek and home country advisors
   • Determine optimal legal framework for succession
   • Create or update testamentary documents
   • Consider pre-inheritance transfers or restructuring
3. Implementation (3-6 months)
   • Execute necessary legal documents with proper formalities
   • Update property registrations and ownership records
   • Address any compliance gaps or outstanding tax issues
   • Create detailed inheritance instructions for executors
4. Regular Review (Annual)
   • Monitor changes in Greek and home country tax laws
   • Update plans with any new assets or family circumstances
   • Verify ongoing compliance with property tax obligations
   • Reassess as diplomatic tax relationships evolve

Beyond the technical aspects, consider the human dimensions of your inheritance planning. What values do you want your Greek legacy to reflect? How might cultural differences affect your beneficiaries’ understanding of your intentions? The most successful inheritance plans address both legal technicalities and family communication.

As you navigate the intersection of Greek heritage and personal legacy, remember that expertise matters. The modest investment in qualified guidance today can preserve significantly more of your estate’s value for future generations, while honoring the special connection you’ve established with Greece.

Have you considered how your Greek assets fit into your broader legacy plan? The time to address these questions isn’t after a crisis, but while you have the clarity and capacity to make thoughtful provisions for the future.

Frequently Asked Questions

Can foreigners inherit property in Greece without restrictions?

Yes, foreigners can inherit Greek property with essentially the same rights as Greek nationals, with some limited exceptions for border areas and certain islands where special permissions may be required. However, non-EU citizens may face additional administrative requirements, including obtaining a Greek tax identification number (AFM) and, in some cases, security clearances for strategic locations. The inheritance process itself follows the same legal framework regardless of nationality, though practical challenges like document authentication and translation requirements create additional steps for foreign heirs.

How long does the Greek inheritance process typically take for foreign beneficiaries?

For straightforward cases with proper documentation, foreign beneficiaries can expect the Greek inheritance process to take 8-14 months from death to final property registration. Complex estates or those with legal complications may extend to 24+ months. Key time factors include: obtaining apostilled death certificates (1-2 months), preparing and filing inheritance tax declarations (2-3 months), tax authority assessment period (3-6 months), issuance of tax clearance certificate (1-2 months after payment), and property registration (1-3 months). Missing documentation, title issues, or family disputes can significantly extend these timeframes.

Can I use my home country will for Greek assets, or do I need a separate Greek will?

While Greece recognizes valid foreign wills, creating a separate Greek will specifically for your Greek assets is highly recommended. A local will drafted in Greek, following Greek legal formalities, streamlines the inheritance process by: eliminating translation and authentication requirements, addressing Greece-specific succession issues directly, enabling tailored tax planning for Greek assets, preventing conflicts between different legal systems, and providing clear instructions for Greek executors familiar with local procedures. The Greek will should be coordinated with your home country estate planning to prevent unintentional contradictions. Many legal experts recommend a “jurisdiction-specific” approach where separate wills govern assets in different countries.

Article reviewed by Charlotte Bennett, Senior Corporate Strategist | Mentor to Next-Gen Leaders | Navigating Business Transitions, on April 29, 2025