Citywealth spoke to Vasileios Tsintzos, Senior Associate at Machas & Partners Law Firm for further insights on the UHNW market and the fabled ‘Golden Visa’. Tsintzos is specialized in the field of investment migration programs; he has a deep knowledge of the regulatory framework and the process of their implementation in Greece, including the Golden Visa project, which concerns investments in real estate, in securities or in state bonds, bank deposits and strategic investments. He has a track record of successfully managing cases related to special tax regimes, especially the ‘non-dom’ tax regime, designed for HNWIs.
Have there been any recent significant regulatory or legislative changes in Greece that are set to impact UHNW individuals or their wealth managers?
“On February 23rd, 2024, an amendment was introduced by the Ministries of Finance, Development, and Investments, aiming to simplify the Greek non-dom tax regime (Ministerial Decision N. 30257 EΞ 2024). This amendment, published in Government Gazette issue 1271/B/23.02.2024, proves the Ministries’ resolution to provide a straightforward process, resolving issues hindering the benefits of this tax regime. It amends Ministerial Decision No. 46834/2023, addressing delays in registering notarial deeds by Land Registries and Cadastral Offices. Certification of investment completion is granted with a one-year extension in pending registration cases (either prior or past their entry to the regime).
Anticipated legislation aims to streamline procedures, notably allowing late family members inclusion, adapting to evolving dynamics and enhancing flexibility in taxation.
By enhancing procedural clarity, Greece solidifies its position as an enticing destination for UHNW individuals seeking alternative taxation options.
The Greek non-dom tax regime entails a lump sum annual tax of €100,000 for all foreign income, with an additional €20,000 for family members. A minimum investment of €500,000 in real estate, bonds/securities, or Greek legal entities is required within 3 years. Only income within Greece is declared, with no inheritance or gift tax imposed on assets held outside, maintaining this advantage for up to 15 years.
The upcoming UK elections on July 4th, coupled with the Spring Budget 2024, introduced significant uncertainty for UK non-doms. Chancellor Hunt’s announcement on March 6th marked a pivotal moment in British tax policy, indicating forthcoming changes in the taxation of non-doms by April 6th, 2025. UK non-doms are considering strategic recalibration for their tax planning and look for better options in other jurisdictions, making Greece an attractive choice, becoming a game-changer for UHNW individuals. Reflecting on this, an upward trend in non-dom tax regime applications is expected.
In addition, the Greek Parliament recently approved significant Golden Visa program amendments, replacing article 100 and par. 49 of article 176 of l. 5038/2023. The minimum eligible real estate investment is now €400,000 in Greece, with specific zones requiring €800,000, and investments must be directed towards a single property, with a minimum surface area of 120 sq.m.
Prospective applicants can benefit from both the Greek non-dom tax regime and the Golden Visa scheme with the same one investment in Greece.”
What is your top-of-mind trend/issue that you are seeing in the private wealth management market in Greece at the moment?
“In Greece’s private wealth management sphere, a noteworthy trend is the increasing demand for personalized financial planning services. Affluent clients are seeking comprehensive solutions covering tax planning, estate planning, retirement strategies and risk management, driven by evolving regulatory landscapes and the complexities of modern markets. Additionally, the real estate sector is thriving, fueled by a resurgence in tourism, while escalating investments in startups and sustainable energy highlight Greece’s commitment to innovation and eco-consciousness. The agricultural sector is also gaining attention for its potential to produce top-quality goods. Amid these trends, wealth managers and UHNW individuals encounter a dynamic landscape filled with opportunities and challenges, enabling them to harness emerging trends to optimize portfolios and achieve long-term financial objectives.”
From an immigration perspective, what are the lesser known benefits and challenges for UHNWIs wanting to reside or conduct business in Greece that they should be aware of?
“Recent amendments to Greece’s Golden Visa scheme now allow UHNW individuals to obtain the Golden Visa with the lower investment threshold of €250,000. This can be achieved by investing in commercial properties like office spaces, convertible for residential use. Similarly, the €250,000 threshold applies to investments in listed buildings, provided restoration follows.
To ease the transition, a transitional period is in place, allowing third-country nationals to swiftly benefit from previous thresholds (€250,000 for all of Greece except specific areas with €500,000) by purchasing property until the end of 2024.
To capitalize on this advantage, applicants must select a property and pay a 10% deposit on the purchase price by August 31st, 2024. The final closing of the property purchase must occur by December 31st, 2024. In case of non-completion, applicants can invest in a different property, with the final transfer contract executed no later than April 30th, 2025.
Golden Visa holders need not worry, as residence permit renewal follows regulations applicable at the time of application. However, recent amendments introduce stringent measures and new program regulations, including the prohibition of leasing properties for short-term rentals. Non-compliance may lead to permit revocation and financial penalties.
Challenges arise from the surge in Golden Visa applications, causing delays in processing and granting permanent residence permits. According to the latest data from the Ministry of Migration, in the first quarter of 2024, applications increased by 12% compared to the previous year. Accumulated applications reached 8,137, with the majority submitted in 2023 and 418 dating back to 2022.
Despite these challenges, Greece’s Golden Visa program remains attractive to UHNW individuals seeking residency, reflecting their continued interest in the country.”
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