Cyprus vs Greece (2026): Non-Dom, 7% Pensioner Flat Tax, 50% Expat Regime & Corporate Tax Head-to-Head

Cyprus and Greece are the two most-asked-about Mediterranean destinations for relocating founders, HNWIs and retirees. Both sit in the EU. Both offer dedicated incentive regimes for newly-arrived taxpayers. Both use the euro. The resemblance stops there. The Greek system is built around three headline regimes (Articles 5A, 5B and 5C of the Income Tax Code) that carve out specific populations and leave the standard Greek tax rules in place for everything else. The Cyprus system is the opposite: low baseline rates, a permanent-feeling non-dom regime, and minimal friction at the residency test. This article compares them head- to-head under the rules in force at April 2026.

One-page summary

Corporate tax: 15% vs 22%

Cyprus raised its corporate income tax rate from 12.5% to 15%effective 1 January 2026, in line with the OECD Pillar Two minimum. Greece's standard corporate income tax rate is 22%. The Greek rate was reduced from 24% in 2022 and has remained at 22% since. Both systems apply to resident companies on worldwide profits; both allow deductions for ordinary business expenses, salaries, depreciation and financing costs (subject to thin-cap and interest-limitation rules).

The 7-percentage-point spread at the company level is the single biggest structural difference. A Cyprus trading company with €1,000,000 of taxable profit pays €150,000; a Greek one pays €220,000 — a difference of €70,000 per year before you even get to shareholder-level tax.

Dividend tax and withholding

Cyprus: zero withholding on outbound dividends paid to non-residents. For Cyprus tax-resident recipients, the SDC is 5% on post-2026 profits (Cyprus-domiciled individuals) or 0% for non-doms. Personal income tax does not apply to dividends.

Greece: a 5% withholding tax applies to dividends distributed by a Greek company, regardless of whether the shareholder is Greek or foreign. EU parent-subsidiary relief applies where the 10%/24-month holding conditions are met. The 5% is final tax for Greek tax-resident individual shareholders (no further PIT on top).

For the foreign shareholder of a trading company, the combined corporate + dividend bill is:

• Cyprus: 15% CIT + 0% WHT = 15% total.
• Greece: 22% CIT + 5% WHT on net = 25.9% total.

The Greek non-dom (€100k flat tax, Article 5A)

Introduced by Law 4646/2019 and codified as Article 5A of the Greek Income Tax Code, the regime lets qualifying high-net-worth individuals who transfer their tax residency to Greece pay a flat €100,000 per year on all their non-Greek-source income, for up to 15 years. Key points:

• Eligibility. Not a Greek tax resident in at least 7 of the 8 tax years immediately preceding the transfer.
• Investment. Commit to invest at least €500,000 in Greek real estate, businesses, securities or bonds within three years.
• Coverage. €100,000 flat covers all non-Greek-source income, regardless of amount. Greek-source income is taxed normally at standard PIT bands.
• Family. Spouse and dependants can be added for €20,000 each per year.
• Duration. Up to 15 years, revocable by the taxpayer at any time.
• CRS reporting. Foreign financial income continues to be reportable via CRS but is not subject to Greek tax beyond the flat sum.

The regime is remittance-style in spirit: bring your wealth (or at least €500k of it) to Greece and get a fixed cost on the rest. It works for the billionaire with €50m of foreign dividends who finds €100k/year a rounding error; it is poor value for someone earning €300k/year in foreign dividends where a non-dom Cyprus structure would charge zero.

The Greek 7% pensioner regime (Article 5B)

Law 4714/2020 created the Greek pensioner incentive: a retired individual who transfers tax residency to Greece can elect to pay a flat 7% on all foreign-source income (pensions, dividends, rents, interest, capital gains) for 15 years. Conditions:

• Non-Greek tax-resident in 5 of the 6 preceding years.
• Prior residence in a jurisdiction that has an administrative cooperation agreement with Greece.
• Election made by 31 March of the tax year.
• 7% applies to ALL foreign-source income, not only pensions.

This is among the most generous retiree regimes in Europe for medium-to-large foreign income streams. A retiree with €200k of combined foreign pension and investment income pays €14,000 per year in Greece — simpler than computing band-by-band PIT.

The Greek 50% expat inbound regime (Article 5C)

Law 4758/2020 (Article 5C) grants a 50% exemption on Greek employment or business income for up to 7 years to new inbound taxpayers who:

• Were not Greek tax residents in 5 of the 6 preceding years;
• Transfer tax residency to Greece;
• Take up employment or self-employment with a Greek employer / permanent establishment;
• Commit to remain at least two years.

50% of the Greek income is exempt from personal income tax AND from the solidarity surcharge. The Cyprus parallel (Article 8(23A)) gives 50% for 17 years — more than twice as long — but requires a higher salary threshold.

The Cyprus non-dom regime

The Cyprus non-dom regime (covered in depth in our dedicated article) exempts qualifying newcomers from the Special Defence Contribution on dividends (5%), interest (17%) and rental income (3%). Duration: 17 years. No investment requirement. No flat fee. No cap on income. Any individual not Cyprus-tax-resident in 17 of the last 20 years qualifies automatically — which means virtually every inbound mover.

The Cyprus 50% expat exemption

Article 8(23A) grants 50% of qualifying Cyprus employment income exempt from personal income tax for up to 17 years, provided the individual was not Cyprus tax resident in any of the 15 years immediately before, and earns above the statutory minimum salary. Unlike the Greek 5C regime, the exemption is 17 years not 7, and it can apply when the employer is the individual's own Cyprus company.

Personal income tax bands

Cyprus 2026

Greece 2026 (employment and pension income)

Cyprus is dramatically more generous at the bottom of the scale (zero to €22,000 vs 9% from the first euro in Greece) and hits its top rate at €72,001 — but only 35%, versus Greece's 44% above €40,000. A Greek solidarity surcharge was suspended for most income in 2023–2025; the standard position at April 2026 is that the surcharge remains suspended for private-sector salaries and pensions but applies in narrow cases; confirm at filing time.

Tax residency: 60 days vs 183 days

Cyprus offers two paths: the standard 183-day test and the 60-day rule (60 days in Cyprus + four conditions, including not being tax resident elsewhere — a condition relaxed in the 2026 reform). Greece uses the 183-day test and a centre-of-vital- interests test. For mobile entrepreneurs, Cyprus is materially more flexible.

Property tax: zero vs ENFIA

Cyprus abolished its annual immovable property tax in 2017. Owners pay nothing recurrent on residential property beyond minor municipal fees (typically €50–€300 per year). Greece charges ENFIA (ΕΝ.Φ.Ι.Α.) every year on all real estate, calculated on the objective value of the property with an additional supplementary tax on portfolios above set thresholds. ENFIA can easily be €1,000–€5,000+ per year on a mid-sized villa.

Transfer taxes on purchase: Cyprus charges graduated transfer fees (1.5–4% on the purchase price for resale properties, waived for new properties subject to VAT); Greece charges a flat 3.09% real-estate transfer tax on resale properties.

Worked case: founder earning €500k dividends + €100k salary

Assume an inbound founder with €500,000 of dividends from a foreign company they own, and €100,000 of local employment income (self-employed director salary in either country).

Cyprus (non-dom + 50% exemption)

• Dividends: 0% SDC (non-dom), 0% PIT. GESY at 2.65% caps at €180k aggregate base → ~€4,770.
• Salary €100,000 with 50% exemption → €50,000 taxable. PIT on €50,000: ~€7,885.
• GESY/SI on €100k salary: within the €180k cap, already accounted above.
• Total tax: ~€12,655 on €600k = ~2.1%.

Greece (Article 5A €100k flat + €500k investment commitment)

• Foreign dividends: covered by €100,000 flat regardless of amount.
• Greek salary €100,000: standard PIT bands → roughly €35,500–€36,000.
• Social contributions on Greek salary: additional substantial layer (not modelled here; applied on capped base).
• Plus €500,000 real-estate / security investment committed within 3 years.
• Total direct tax: ~€136,000 on €600k = ~22.7%, plus locked capital.

Greece (no special regime)

• €500k foreign dividends taxed at 5% = €25,000.
• €100k salary at Greek PIT bands ~€35,500.
• Total: ~€60,500 on €600k = ~10.1%, plus social contributions.

On this profile Cyprus wins decisively. The Greek 5A regime only becomes competitive when foreign passive income is very large (north of €2–3 million per year), because the €100,000 flat ceases to be meaningful as a percentage.

Who should pick Greek 5A vs Cyprus non-dom

Pick Greece Article 5A if:

• Foreign passive income > €2–3 million/year.
• You want to live in Athens / mainland Greece for lifestyle.
• You are willing to lock €500,000 into Greek assets.
• You value certainty of a fixed euro-amount tax bill.

Pick Greece Article 5B if:

• You are a retiree with foreign pension / investment income of €30k–€500k.
• You prefer the Greek lifestyle and climate.
• You are comfortable being Greek tax resident on a 183-day basis.

Pick Cyprus non-dom if:

• You run a trading company (CIT 15% beats 22%).
• You want light residency (60-day rule).
• You want 0% on dividends — not a flat fee.
• You want zero annual property tax and zero inheritance tax.
• Your foreign income is between €100k and €2m (the sweet spot where Cyprus non-dom materially beats the Greek flat).

Many founders we advise end up comparing Cyprus and Greece side by side. If Greece is the better fit for your profile we run that process through our Greek relocation service. If Cyprus wins, see our non-dom guide and the 60-day rule.