Από την Ελλάδα στην Κύπρο

Greek founders in 2026: post-5246/2025 scale, 5% dividend WHT, ENFIA, and the 15% crypto regime

Law 5246/2025 (Mitsotakis' Thessaloniki-Fair reform) cut Greek PIT bands by 2pp each from 2026 — but 44% top marginal still bites above €60k. Add 5% dividend WHT, 22% IRC, ENFIA, and the newly-announced 15% crypto tax, and the Cyprus route becomes the cleanest way for Greek founders to step up structurally. Both are EU Member States with a long-standing DTT — relocation is lawful, permitted under freedom of movement, and non-blacklisted.

✓Law 5246/2025 scale: 9%/20%/26%/34%/39%/44% — Cyprus tops at 35%
✓5% dividend WHT + 22% IRC = ~25.9% on distributed profits — Cyprus non-dom ~17.5%
✓15% flat crypto tax from 2026 — Cyprus 8% Article 20E + non-dom exemption
✓ENFIA on property portfolios — Cyprus has no annual recurrent property tax since 2017

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Greece vs Cyprus at a glance

All figures verified against primary sources listed at the bottom of the page. Estimates, not legal or tax advice.

What matters	Greece	Cyprus
Corporate tax	22% flat IRC; credit institutions higher (29%)	15% flat from 2026; IP Box effective ~3%
Top personal income tax	44% above €60,000 (Law 5246/2025 scale from 2026); previously bit at €40k	35% top marginal; 0% up to €22,000
Dividend WHT	5% (down from 10% since 2020)	Non-dom: 0% SDC on dividends for 17 years
Capital gains on shares	15% flat (exemption for <0.5% holdings in listed companies)	0% on non-real-estate shares
Crypto	15% flat on net gains (2026, losses carry 5 years)	8% flat under Article 20E (2026) + non-dom exemption
Property tax (ENFIA)	Main ENFIA (banded per property) + supplementary surcharge on estates >€400k at 0.15–1.15%	No annual recurrent property tax (since 2017)
HNW / expat regimes (Greece)	Art. 5A €100k flat on foreign income (15 yrs, €500k investment); Art. 5B pensioners 7% flat (15 yrs); Art. 5C digital-nomad 50% exemption (7 yrs)	Non-dom 17 years, no minimum investment; 50% exemption on salary >€55k for 17 yrs
Days test	Permanent residence / habitual abode / centre of vital interests; 183-day physical presence	183-day rule OR 60-day rule with Cyprus ties

Why Greek founders are looking at Cyprus in 2026

Law 5246/2025 cut bands but kept 44% top

Greece's 2026 PIT scale (effective 1 January 2026 per Law 5246/2025) cut bracket rates by 2 percentage points each but kept the top marginal at 44% — it now bites above €60,000 (previously €40,000). New 2026 scale: 9% to €10k, 20% to €20k, 26% to €30k, 34% to €40k, 39% (new band) to €60k, 44% above. The solidarity contribution (εισφορά αλληλεγγύης) was permanently abolished from 1 Jan 2023 and does not return. KPMG — Law 5246/2025 flash alert.

~25.9% effective on distributed Greek corporate profits

A Greek ΑΕ or ΕΠΕ pays 22% IRC, then 5% dividend WHT on the net distribution — combined effective ~25.9% on profits extracted to the owner. A Cyprus company pays 15% CIT (from 2026) and, for a non-dom shareholder, 0% SDC on the dividend + 2.65% GESY capped = ~17.5% combined. On €500,000 of annual distributed profits, the Greek route costs ~€130,000; the Cyprus route ~€88,000 — roughly €42,000/year of operating-level savings without touching the business model.

The new 15% crypto regime + CARF/DAC8 reporting

Greece introduced a 15% flat rate on net crypto capital gains for 2026, with losses offsetable in the same year and 5-year carry-forward. Combined with the EU's DAC8 and OECD's CARF cross-border reporting starting in 2026, Greek tax authorities will automatically receive data on crypto holdings at foreign exchanges. Cyprus introduced Article 20E from 1 January 2026: an 8% flat rate on crypto gains for traders — 7 percentage points lower. For long-term investor-style holdings, Cyprus non-dom treatment can often place gains entirely outside the SDC net.

ENFIA + supplementary surcharge hits real-estate-heavy portfolios

Greek property tax (ENFIA) is annual and stacks two layers: Main ENFIA (banded by location, age, size — typical effective rate 0.05%–0.8% of tax-assessed value) plus a supplementary surcharge on personal real-estate portfolios above €400,000 (progressive 0.15%–1.15%). Law 5246/2025 introduced reductions for small villages (<1,500 inhabitants) and announced full abolition there from 2027, but headline ENFIA on valuable property stays. Cyprus has no annual recurrent property tax since 2017 — only transfer fees on acquisition and modest municipal rates. AADE — ENFIA user guide.

Greek HNW regimes are strong — but tied to Greek investment

Greece's non-dom offers are competitive: Art. 5A delivers €100,000/year flat on foreign income for 15 years (requires €500k investment in Greece + 7/8 years non-resident). Art. 5B offers 7% flat on foreign pensions for 15 years. Art. 5C gives a 50% exemption on Greek salary for 7 years for digital-nomad and new-employee profiles. But Art. 5A requires the €500k investment tying capital in Greece, and Art. 5B is pension-specific. Cyprus non-dom has no minimum investment, no €100k lump sum, 17-year base duration extending to 22 years free (and up to 27 years via €250k paid extensions). For founders with variable income, the Cyprus proportionality wins at most income levels.

Leaving Greece: what breaks residency and what follows you

Residency test (Art. 4, Law 4172/2013). You're Greek-resident if any of: (1) permanent or principal residence in Greece; (2) habitual abode; (3) centre of vital interests (personal and economic ties — family, main activity, principal assets); (4) Greek diplomatic/consular post abroad as a Greek national. Also: >183 days in any 12-month period triggers residency from day one (except purely tourist/medical stays up to 365 days).

DOY de-registration. Transfer of residence must be filed at the competent Tax Office for Non-Residents (ΔOY Κατοίκων Εξωτερικού), with supporting certificates of tax residency from the new state. Failure to file can leave Greece asserting residency.

No general individual exit tax. Greece does NOT impose a deemed-disposal exit charge on unrealised gains on shares, securities, or crypto when an individual transfers tax residence abroad. This is a material simplification compared to Germany, France, or Spain.

Corporate exit tax (Art. 66A, Law 4172/2013). Applies only to legal persons/entities and Greek PEs, triggered by transfers of assets or seat abroad (ATAD transposition from 1 January 2020).

Greek-source income post-departure. Non-residents remain subject to Greek tax on Greek-source income: Greek real-estate rental, Greek company dividends at 5% WHT, ENFIA on Greek real estate, Greek-employment days, Greek pensions (with treaty carve-outs).

The Greece–Cyprus double tax treaty

The Greece-Cyprus DTT was signed on 30 March 1968 — one of Cyprus's oldest DTTs, still in force with MLI amendments. Dividends: Greek domestic 5% WHT applies (lower than treaty cap); Cyprus imposes 0% WHT on outbound dividends to non-residents under domestic law. Interest: 10% treaty cap; Cyprus outbound 0%. Royalties: 5% on certain film royalties under treaty; other royalties at treaty rates. Tie-breaker (Art. 4): standard OECD cascade — permanent home → centre of vital interests → habitual abode → nationality → mutual agreement. For intra-EU corporate shareholdings ≥10%, the EU Parent-Subsidiary Directive can deliver 0% at source independently of the treaty.

FAQs

Can I keep my Greek AE and just move personally to Cyprus?

Yes — the Greek company remains Greek-resident for IRC regardless of where you live. Distributions to you as a Cyprus tax resident will suffer 5% Greek dividend WHT at source (or potentially 0% under EU Parent-Subsidiary Directive if you hold via a qualifying Cyprus corporate parent with ≥10% stake for ≥24 months). For Cyprus non-doms, the 5% received then faces 0% SDC in Cyprus, plus 2.65% GESY capped. Compared to keeping everything Greek (22% IRC + 5% WHT + any ENFIA on property = €27+% effective), the €500k dividend saves ~€40–50k/year.

Greece's Art. 5A non-dom gives €100k/year flat on foreign income. Why would I leave?

Three reasons: (1) Art. 5A requires a €500,000 investment in Greece within 3 years — capital locked in. (2) The lump sum is flat regardless of your income — so if your foreign dividends are €300k, €100k is 33% effective which is worse than Cyprus non-dom's 0% SDC + 2.65% GESY. (3) Art. 5A protects only foreign-source income; Greek-source income (including any salary you draw) still pays progressive PIT up to 44%. Cyprus non-dom is proportional, has no entry fee, and runs 17 years.

What happens to my ENFIA if I keep Greek property but move?

ENFIA continues to apply — it's a tax on the property, not on you personally. Main ENFIA and the supplementary surcharge remain due while you own Greek real estate. Moving to Cyprus doesn't eliminate ENFIA; only selling the property (or transferring to a Greek-registered legal entity with different ENFIA treatment) does. On the Cyprus side, you pay no Cyprus annual property tax on properties you acquire there.

I'm a pensioner. Is Art. 5B or Cyprus's flat 5% pension regime better?

Depends on the pension size. Art. 5B is 7% on all foreign-source income for 15 years (not just pensions — also foreign dividends, interest, rental). Cyprus's foreign-pension option is 5% flat on amounts above €3,420 per year (progressive PIT under €3,420), but ONLY on pensions. Cyprus non-dom then gives 0% SDC on foreign dividends/interest. Broadly: if your income is pension + some foreign investment, Cyprus typically wins (5% pension + 0% investment SDC vs Greek 7% on everything). If your income is heavily foreign-active-business, Greek Art. 5B can be simpler. We model both.

Does Greece's 15% crypto rate catch me on the way out?

Greece does NOT have a crypto exit-tax deemed-disposal rule analogous to Portugal's. The 15% crypto rate applies to realisations while you're Greek tax resident. If you hold crypto and don't realise before the move, the gain is not taxed in Greece on exit — it's taxed on eventual realisation by your new residence jurisdiction. In Cyprus, realisation under Article 20E is 8% flat for traders; non-dom investors may be outside Cyprus tax entirely.

How long does a Greece-to-Cyprus relocation actually take?

Typically 3–4 months end-to-end: 2–3 weeks to set up a Cyprus company and tax residence, 4–6 weeks for immigration (Yellow Slip — Greeks as EU citizens move freely, just register), 4–8 weeks for Cyprus banking, and parallel work on the Greek side (DOY Κατοίκων Εξωτερικού transfer, ΑΑΔΕ notifications, property management arrangements). For owners of Greek AEs with active operations, add 1–2 months of corporate planning (dividend timing, ENFIA filings, potential seat-transfer analysis).

Page last reviewed April 2026. This page provides general estimates only — not legal, tax or financial advice. No solicitor–client relationship is created by reading it. Personal situations depend on family, source of income and timing. Book a free consultation for written advice.

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