Significant changes to the procedure for foreign pensioners seeking to qualify for the special tax regime under Article 5B of Law 4172/2013 have been introduced by Law 5313/2026 and the recent Decision A.1192/2026 of the Governor of the Independent Authority for Public Revenue (IAPR). The regime continues to provide for separate taxation at a flat rate of 7% on foreign-source income for a period of up to 15 tax years, subject to the applicable statutory requirements.
One of the most significant changes concerns the extension of the application deadline from 31 March to 31 October of each year. Specifically for 2026, since 31 October fell on a Saturday, the deadline was extended to 2 November 2026. At the same time, more specific rules have been introduced regarding the tax year for which admission to the regime may be requested. In particular, taxpayers who transfer their tax residence to Greece on or before 2 July may apply for admission to the regime either for the same tax year or for the following tax year, whereas taxpayers who transfer their tax residence after that date may only apply for admission for the following tax year. Furthermore, applicants are permitted to submit any outstanding supporting documentation until 30 November of the year in which the application is filed, even if the initial application is incomplete. The Tax Administration is required to examine applications within 60 days and, in any event, to issue its decision no later than the last working day of December. Another important change is the postponement of the deadline for payment of the 7% tax from July to the last working day of December. The tax remains payable in a single lump sum, without the possibility of an instalment payment arrangement, while failure to pay the full amount results in the loss of eligibility for the special tax regime.
The new provisions also have transitional application, covering pending applications submitted before 25 June 2026, as well as applications submitted subsequently that remain pending. In addition, Decision A.1192/2026 regulates matters relating to administrative tax assessment acts for the 2025 tax year and replaces the previous regulatory Decision A.1217/2020.
Overall, the new legislative and regulatory framework provides greater flexibility for prospective applicants and clarifies the procedure for submitting and examining applications, without altering the fundamental structure of the special tax regime. The 7% tax rate remains unchanged, while the relevant Double Taxation Agreements continue to apply. Greek-source income remains subject to taxation under the general provisions of the Greek Income Tax Code. Eligibility for the regime continues to depend on compliance with the statutory requirements governing the transfer of tax residence and requires an individual legal and tax assessment, particularly in cases involving cross-border income.
MStR Law Firm, with experience in international tax law and cross-border transfers of tax residence, provides comprehensive legal assistance to pensioners wishing to relocate to Greece and benefit from the special tax regime under Article 5B of the Greek Income Tax Code. The firm’s services include assessing eligibility requirements, examining the tax implications of transferring tax residence, preparing and submitting the relevant applications, and representing applicants before the competent tax authorities. Our objective is to ensure the proper application of the applicable tax framework and the effective management of the legal and tax issues arising from the transfer of tax residence to Greece.