Portugal vs Greece Tax Comparison
Greece has created multiple pathways for high-net-worth individuals and pensioners to minimize tax burden. These regimes operate under Articles 5A, 5B, and 5C of the Greek Income Tax Code and represent some of the most generous incentives in Europe. This is Greece's headline incentive for entrepreneurs and employees relocating to the country. Ready to plan your Portugal tax position with confidence? Scope and fee confirmed in writing before work begins.
- Chapter I: Quick Comparison Table
- Chapter II: Understanding Greece's Non-Resident Tax Incentives
- Chapter III: Portugal's IFICI Regime: The New NHR Alternative (2025)
- Chapter IV: Inheritance and Estate Planning
- Chapter V: Property Taxation and Real Estate Investment
- Chapter VI: Income Tax Rates and Brackets
- Chapter VII: Corporate Taxation
Quick Comparison Table
Tax Category Portugal Greece
Foreigner/Expat Income IFICI: 20% on qualifying income Article 5C: employment-income incentive (time-limited) Foreign-Source Income Exempted under IFICI €100K lump sum or 50% exemption Inheritance (Direct Family) 0% 1–10% (progressive) Capital Gains (Real Estate) Standard resident/non-resident rules apply Temporary relief periods may apply under Greek law; verify current status Capital Gains (Shares) Normal rates apply 15% Corporate Tax 19% 22% Property Tax (ENFIA) Not applicable €2–€16.20 per sq.
Tax Category Portugal Greece Foreigner/Expat Income IFICI: 20% on qualifying income Article 5C: employment-income incentive (time-limited) Foreign-Source Income Exempted under IFICI €100K lump sum or 50% exemption Inheritance (Direct Family) 0% 1–10% (progressive) Capital Gains (Real Estate) Standard resident/non-resident rules apply Temporary relief periods may apply under Greek law; verify current status Capital Gains (Shares) Normal rates apply 15% Corporate Tax 19% 22% Property Tax (ENFIA) Not applicable €2–€16.20 per sq. metre Pensioner Regime Standard rates 7% flat (15 years)
Supporting content
- Primary source: Codigo do IRS (CIRS) - Portuguese Personal Income Tax Code
- Book a Tax Consultation
Understanding Greece's Non-Resident Tax Incentives
Greece has created multiple pathways for high-net-worth individuals and pensioners to minimize tax burden.
Greece has created multiple pathways for high-net-worth individuals and pensioners to minimize tax burden. These regimes operate under Articles 5A, 5B, and 5C of the Greek Income Tax Code and represent some of the most generous incentives in Europe.
Article 5C: The 50% Employment Income Exemption This is Greece's headline incentive for entrepreneurs and employees relocating to the country. Tax Benefit: Exemption from 50% of income tax and solidarity contribution on earnings derived from employment or business activity conducted in Greece. The exemption applies to the net income earned within Greece.
Duration: Up to 7 consecutive tax years from the year you become a tax resident. Eligibility: You may need to:
- Transfer your tax residence to Greece
- Not have been a Greek tax resident for the previous 7 of 8 years
- Meet the specific Article 5C legal criteria in force (employment-focused pathway)
Practical Impact: Effective savings depend on how Greek law defines eligible income, duration, and filing conditions in the year of claim. Article 5A: The €100,000 Lump Sum Alternative For ultra-high-net-worth individuals with substantial foreign income, Greece offers a flat annual tax of €100,000. Tax Benefit: Pay €100,000 per year, regardless of total foreign-source income.
No additional taxation on dividends, interest, or capital gains from abroad. Duration: Up to 15 fiscal years. Eligibility: You may need to:
- Have not been a Greek tax resident for 7 of the prior 8 years
- Meet the Article 5A/5B/5C criteria that apply to your chosen pathway
When It Works Best: If your annual foreign income exceeds €500,000, the lump sum becomes highly attractive. Someone earning €1 million abroad pays only €100,000 tax under this regime. Article 5B: Pensioner Flat Tax (7% for 15 Years) Greece's pensioner regime is arguably Europe's most competitive for retirees.
Tax Benefit: A flat 7% tax rate on foreign-source pension income (including public and private pensions, annuities). Duration: 15 consecutive tax years (longest in Europe).
Eligibility: You may need to:
- Receive a foreign pension (public or private)
- Not have been a Greek tax resident for 5 of the prior 6 years
- Be a tax resident of a country with a double-taxation treaty with Greece
- Spend at least 183 days annually in Greece (tax residency requirement) Practical Impact: A retiree with €50,000 annual pension income pays €3,500 tax under Article 5B, versus €7,000–€9,000 under standard Greek rates (22%–28%)
Supporting content
- Primary source: Portugal bilateral tax treaty text (AT list)
- Book a Tax Consultation
Portugal's IFICI Regime: The New NHR Alternative (2025)
Portugal closed NHR to new entrants effective January 1, 2024 (Law 82/2023) and introduced IFICI as the successor framework for qualifying professional activity.
IFICI: 20% Flat Rate on Portuguese Income Tax Benefit: A 20% flat personal income tax on employment and self-employment income earned in Portugal from eligible activities. Foreign-source income (dividends, interest, capital gains) is exempt from Portuguese taxation. Duration: 10 consecutive years.
Income Categories Exempt: Categories E, F, and G (dividends, interest, rental income, capital gains) face zero Portuguese tax under IFICI.
Eligibility Restrictions:
- may need to hold a university degree (EQF Level 6+) or doctorate
- may need to work in sectors: science, technology, healthcare, green energy, or research and development
- may need to not have been a Portuguese tax resident in the prior 5 years
- typically may not have previously benefited from NHR or Portugal's Return Programme
- may need to submit application by 15 January of the year following your tax residency establishment Key Limitation: IFICI is narrower than the old NHR
It excludes artists, athletes, and non-research professionals. If your profession doesn't fall into eligible categories, you pay standard Portuguese income tax (14%–48% progressive scale). Application Timeline: Application windows are regime-specific and should be confirmed with current AADE guidance before relying on historical dates.
Supporting content
- Primary source: Codigo do IRS (CIRS) - Portuguese Personal Income Tax Code
- Book a Tax Consultation
Inheritance and Estate Planning
Inheritance taxation differs dramatically between these countries, making estate planning essential.
Portugal: Tax-Free Direct Family Inheritance Portugal offers one of Europe's most favorable inheritance frameworks. Direct Family (0% Tax):
- Spouses
- Children
- Grandchildren
- Parents
- Grandparents These beneficiaries pay zero inheritance tax, only a 0.8% property transfer duty on real estate (10% stamp duty applies to non-family transfers)
Non-Direct Heirs (10% Stamp Duty):
- Siblings, distant relatives, unrelated individuals pay 10% stamp duty
- Real estate inheritance adds an additional 0.8% property transfer duty Strategic Advantage: A wealthy parent can transfer a €500,000 estate to a child entirely tax-free, saving €25,000–€50,000 compared to Greece
Greece: Progressive Graduated Rates by Relationship Greece employs a complex, relationship-based system with higher rates but exemption thresholds. Immediate Family (Spouses, Children, Grandchildren, Parents):
- Tax-exempt up to €150,000
- Above €150,000: progressive rates from 1% to 10%
- Example outcomes are sensitive to family category, exemptions, and current Greek inheritance-law tables
Siblings and Grandparents:
- Tax-exempt up to €30,000
- Progressive rates 20%–40% above threshold Distant Relatives and Unrelated Persons:
- Tax-exempt up to €6,000
- Progressive rates 20%–40% Net Effect: While Greece appears more generous with exemption thresholds, Portugal's zero rate for direct family makes it superior for most expat scenarios
Supporting content
- Primary source: Codigo do IRS (CIRS) - Portuguese Personal Income Tax Code
- Book a Tax Consultation
Property Taxation and Real Estate Investment
Property ownership carries different annual burdens in each country.
Greece: ENFIA Annual Property Tax Tax Rate: €2–€16.20 per square metre annually, depending on location and property characteristics.
Calculation Factors:
- Cadastral value (replacement cost basis)
- Size, use, and age of property
- Floor number and number of building facades
- Geographic location (Athens center, island locations command premium rates) Example: A modest 80 sq.m apartment in Athens might face €400–€800 annually. Prime Mykonos or Santorini properties face €1,200–€2,000+ per annum
Property-tax incentives: insured-property reductions and related relief programs are policy-dependent and should be validated under current AADE rules. Payment: ENFIA can be paid in 12 monthly installments beginning March each year. Capital Gains on Property Sales Greece: Real-estate capital-gains treatment has had temporary relief periods and reinstatement discussions. Confirm the active rule and end-date before transaction planning.
Portugal: Capital gains on real estate fall under standard income taxation. Non-residents may face 28% taxation; residents typically pay lower rates if held for long periods.
Supporting content
- Primary source: Codigo do IRS (CIRS) - Portuguese Personal Income Tax Code
- Book a Tax Consultation
Income Tax Rates and Brackets
Understanding the baseline income tax system is essential if preferential regimes don't apply.
Greece: 2025 Income Tax Brackets Greece employs a progressive system with five brackets: Annual Income Tax Rate €1–€10,000 9% €10,001–€20,000 22% €20,001–€30,000 28% €30,001–€40,000 36% Over €40,000 44% Allowances and credits: age-based relief, credits, and solidarity mechanisms are frequently updated and should be validated in current-year Greek guidance.
Portugal: Progressive Scale (Without IFICI) If IFICI does not apply: Annual Income Range Tax Rate Up to €10,536 14.5% €10,536–€20,322 21% €20,322–€40,005 26% €40,005–€80,882 37% Over €80,882 45% Standard brackets are more compressed than Greece but reach 45% versus Greece's 44% at the top end.
Supporting content
- Primary source: Codigo do IRS (CIRS) - Portuguese Personal Income Tax Code
- Book a Tax Consultation
Corporate Taxation
For business owners, corporate tax rates differ modestly.
Greece: 22% Standard Rate The Greek corporate income tax rate is 22% for most entities. Credit institutions and financial entities face 29%. Incentive: Businesses relocating under Article 5C may claim the 50% income reduction on employment earnings, but the corporate entity itself pays standard 22% rates on profits.
Portugal: 19% Standard Rate Portugal's corporate tax rate is 19%, providing a 3-percentage-point advantage over Greece for business entities. Municipal Surcharge: An additional municipal business tax (derrama municipal) of up to 1.5% may apply depending on municipality. Effective Combined Rate: Portugal's corporate tax may reach 20.5%, still competitive with Greece's 22%.
Supporting content
- Primary source: Codigo do IRS (CIRS) - Portuguese Personal Income Tax Code
- Book a Tax Consultation
Primary sources (verified on 24 February 2026): Portal das Finanças, Diário da República, EUR-Lex, IRS, FinCEN, GOV.UK.
⚠️ CONFIRMAÇÃO NECESSÁRIA / CONFIRMATION NEEDED: cross-border outcomes depend on your residency facts, treaty article mapping, income category, and filing year.
Treaty anchor note (for cross-border cases): depending on treaty and income type, analysis may require Article 4 (residency tie-breaker), Article 15 or Article 18 (income allocation), and Article 23 (double-tax relief method). Confirm the exact treaty text in force for your countries and tax year.
Next Steps: Book Your Tax Consultation
Frequently Asked Questions
These FAQs address the most common questions about Portugal vs Greece Tax Comparison.
For €100,000 earned in Greece under Article 5C: 50% exemption applies, leaving €50,000 taxable at approximately 22%–28% = €11,000–€14,000 tax. Effective rate: 11%–14%. For €100,000 in Portugal under IFICI: 20% flat = €20,000 tax. Effective rate: 20%. Answer: Greece's Article 5C is superior if income is Greece-source. However, if income is foreign-source, Portugal's IFICI may exempt it entirely under certain conditions.
No. Tax residency is location-based. You establish residency in one country and claim that country's regime. You typically may not claim both simultaneously. However, strategic planning may allow you to spend time in both countries while maintaining primary residency in one. Consult a cross-border tax advisor before planning dual residency.
After 7 years, the 50% exemption expires. You then face standard Greek income tax rates (9%–44%). Many high-income individuals plan to relocate to another jurisdiction, shift to pensioner status if eligible, or accept the standard rates.
Yes. Additional costs include:
- Municipal property tax (when property changes ownership)
- Real estate transaction tax (~€100–€300 per transfer)
- Notary and registration fees
- Ongoing maintenance For a €500,000 property purchase, expect €20,000–€40,000 in acquisition costs
Yes, for certain income categories. IFICI exempts foreign-source capital gains, dividends, and interest (Categories E, F, G). Portuguese-source capital gains are taxed normally at the individual's marginal rate, unless held as a long-term investment (varies by structure).
This refers to the professional credential of Telmo Ramos, founder of Taxbordr, registered with the Portuguese Economists Association (Ordem dos Economistas). This Cédula No. 16379 certification ensures compliance with Portuguese tax and financial advisory standards and demonstrates professional accountability in cross-border tax matters. Book a Tax Consultation
Contributors
Telmo Ramos
Founder, Taxbordr | Ordem dos Economistas Cédula No. 16379
Sources
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