Tax Treaty Relief in Greece

How many double-tax treaties does Greece have, and what is the credit method?

Greece has signed approximately 57 double-tax conventions (DTTs) in force as of 2026, covering all 27 EU member states plus major non-EU partners including the United States, United Kingdom, Canada, Australia, China, India, Japan, Switzerland, Saudi Arabia, the UAE, Qatar, Singapore, and South Africa. The official treaty register is maintained by AADE (Independent Authority for Public Revenue) at its International Issues section.

Of these 57 DTTs, 56 apply the credit method for elimination of double taxation (broadly matching OECD Model Article 23B): a Greek tax resident who pays tax abroad on foreign-source income may credit that foreign tax against their Greek income tax liability, subject to a cap equal to the Greek tax that would have been due on the same income. Only the Greece-India DTT applies the exemption method. The credit is computed per-country; no cross-country pooling. Excess credits not absorbed in the year of accrual may generally be carried forward. Where no treaty applies, Greek domestic law (Article 9 of Law 4172/2013, the Income Tax Code) provides a comparable unilateral credit capped at the Greek tax on that same foreign income. Documentary requirements include an apostilled copy of the foreign tax return and payment notice, together with an official Greek translation.

What are the domestic withholding rates and how do key treaties reduce them?

Greece's domestic withholding tax rates on payments to non-residents are: dividends 5%, interest 15%, and royalties 20% under Article 64 of the Income Tax Code. The 5% dividend rate was reduced from 15% by Law 4549/2018 and is among the lower domestic dividend withholding rates in the EU.

Treaties can reduce these rates further. The table below shows representative treaty withholding-tax (WHT) ceilings for dividends (DIV), interest (INT), and royalties (ROY) across key partners. Where a treaty provides two rates, the lower rate applies to qualifying corporate shareholders above a specified holding threshold (typically 10% or 25%), while the higher rate applies to portfolio investors.

Note: rates marked "domestic" indicate the treaty does not override the domestic rate on that income type. The France treaty provides 0% dividends where the recipient has held at least 5% for 24 months. Germany and the US/UK treaties provide 0% royalties. Japan and Singapore treaties provide 0% interest in certain bank-loan situations. All figures are treaty-rate ceilings; the lower of the treaty ceiling and the domestic rate applies.

How does the residence tie-breaker resolve dual-resident cases?

Greek domestic law taxes individuals as residents if they maintain their permanent or principal home, habitual residence, or centre of vital interests in Greece, or if they are present in Greece for more than 183 days in any 12-month period commencing or ending in the tax year. The 183-day count covers continuous and intermittent presence; purely touristic or medical stays may be excluded.

Where an individual is resident under both Greek domestic law and the domestic law of a treaty partner (dual residency), the treaty's tie-breaker cascade (modelled on OECD Model Article 4(2)) resolves the conflict in this order: (1) permanent home -- the state in which the individual has a permanent home available; (2) centre of vital interests -- personal and economic ties; (3) habitual abode -- where the individual stays more regularly; (4) nationality; (5) mutual agreement by the two competent authorities. Greece applies this cascade in accordance with OECD Commentary. The tie-breaker determines which state may tax worldwide income as the residence state, while the other state's taxing rights are limited to source-state income under the relevant treaty articles.

For corporate entities, dual-residency tie-breakers follow the place-of-effective-management test under most Greek DTTs; the MLI modifies certain covered agreements to require mutual agreement between competent authorities rather than automatic resolution.

How does a non-resident claim treaty-reduced withholding on Greek-source income?

A non-resident receiving Greek-source dividends, interest, or royalties may claim treaty-reduced withholding through two routes, both administered by AADE.

The at-source relief route requires the non-resident to present to the Greek withholding agent (the paying company, bank, or licensee) a completed bilingual claim-for-relief application together with a Tax Residence Certificate (TRC) issued by the competent tax authority of the non-resident's country of residence. AADE maintains country-specific claim-for-relief application forms (available at the AADE forms portal) in Greek and English (or the relevant partner-language). The paying agent then withholds at the treaty-reduced rate rather than the domestic rate.

The refund route applies where domestic-rate withholding has already been deducted. The non-resident files an Annual Claim to Refund of Income Tax with the relevant AADE tax office, attaching the TRC and supporting income documentation. The refund claim must be filed within five years of the end of the assessment year (Article 36 of the Tax Procedure Code, Law 4174/2013).

For Greek residents claiming treaty protection in the source country (outbound), AADE issues a digital Tax Residence Certificate via the TAXISnet portal (path: myAADE > Registry and Communication > Tax Residence Certificate). Since May 2023 the TRC is issued digitally, instantly upon submission, in Greek and English, bearing a unique issue number and an AADE electronic seal. It is submitted to the foreign withholding agent or competent authority to establish Greek tax-residency status.

What did Greece adopt under the OECD Multilateral Instrument?

Greece signed the MLI on 7 June 2017 and deposited its ratification instrument on 30 March 2021 (Law 4768/2021). The MLI entered into force for Greece on 1 July 2021. Greece notified 41 covered tax agreements at signature.

Greece adopted the Principal Purpose Test (PPT) under MLI Article 7(1) as the minimum-standard anti-avoidance provision. Under the PPT, treaty benefits are denied if one of the principal purposes of an arrangement or transaction was to obtain those benefits, unless granting the benefit would be consistent with the object and purpose of the treaty. Greece opted out of the Simplified Limitation on Benefits (SLOB) clause as an alternative. Greece also opted out of the hybrid-mismatch provisions (Articles 3-5 MLI) and the artificial PE-avoidance provisions (Articles 12-15 MLI).

Greece opted in to mandatory binding arbitration under Part VI MLI, extending this mechanism to covered agreements with key bilateral partners. For withholding taxes, MLI changes applied to amounts withheld from the first calendar year beginning after 1 July 2021 -- in practice, from 1 January 2022. Synthesised treaty texts for the 41 covered agreements are published by AADE.

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How do EU directives reduce withholding on intra-EU flows?

Within the EU, two directives operate alongside bilateral DTTs and often deliver more favourable withholding rates.

The Parent-Subsidiary Directive (Council Directive 2011/96/EU, transposed in Greece via Article 48 of the Income Tax Code) eliminates withholding entirely (0%) on dividends paid by a Greek subsidiary to an EU parent company holding at least 10% of the capital of the Greek company for at least 24 months. The 24-month holding requirement is more stringent than the Directive's minimum one-year floor. A bank guarantee permits anticipatory application before the 24 months expire. The beneficial-ownership test under CJEU case law (T Danmark, C-116/16) applies: conduit structures lacking genuine economic substance do not qualify.

The Interest and Royalties Directive (Council Directive 2003/49/EC) eliminates withholding (0%) on interest and royalty payments between associated EU companies (25% capital link for at least two years). Greece was granted a transitional period under the Directive, which has since lapsed; full 0% rates now apply for qualifying intra-EU payments.

EU-route exemptions and treaty-route reductions are mutually exclusive claim paths; whichever delivers the better outcome (typically the EU Directives for qualifying EU-to-EU flows) is chosen in practice. See the Greece country overview for broader context on Greece's tax environment.

How do the non-dom regimes interact with treaties?

Greece introduced three alternative tax regimes in Law 4172/2013 for individuals who transfer their tax residence to Greece:

Article 5A (investors): individuals who were not Greek tax residents for at least 7 of the preceding 8 years and who invest at least EUR 500,000 in Greece pay a flat EUR 100,000 lump-sum tax per year on all foreign-source income, regardless of actual foreign income amount, for up to 15 years. Foreign taxes paid on income covered by this regime cannot be credited against the EUR 100,000 lump sum -- the flat charge exhausts Greek liability on foreign-source income. Greek-source income remains taxable under normal rules and is fully eligible for treaty relief and the standard credit framework. Family members may join at EUR 20,000 per person per year.

Article 5B (pensioners): individuals receiving a foreign pension who were not Greek residents for at least 5 of the preceding 6 years, and who relocate from a jurisdiction with which Greece has an administrative-cooperation agreement, pay a flat 7% rate on all foreign-source income for up to 15 years. The 7% regime explicitly preserves access to DTTs; foreign tax paid may be credited where the relevant DTT provides for it.

Article 5C (professionals): EU/EEA residents relocating to Greece for employment or business receive a 50% income exemption on Greek-source employment and business income for up to 7 years. Foreign-source income is taxed normally.

All three regimes preserve the individual's status as a Greek tax resident for DTT purposes -- they may obtain a Greek TRC and claim treaty residence. The regimes are mutually exclusive; applications are due by 31 March of the relevant tax year.

Complex cross-border treaty-residency questions, beneficial-ownership documentation for Parent-Subsidiary Directive claims, and Art 5A/5B applications require the guidance of a qualified tax professional. Consult the Greece country overview to locate vetted professionals in Greece.