About Taxbordr: founder-led PT vs GR analysis
Taxbordr is a Portugal tax advisory firm founded by Telmo Ramos, Ordem dos Economistas Cédula nº 16379, formerly KPMG Luxembourg and EY Lisbon. We model PT versus GR decisions for HNW families, retirees from the UK, Germany, the United States, and Northern Europe choosing between Lisbon, Porto, the Algarve, Athens, and the Greek islands. The deliverable is a written Position Memo signed by Telmo, with side-by-side regime, capital gains, real estate, and exit-cost lines. Greek-side numerical positions are coordinated with Greek counsel where the case warrants.
Greek regimes: three different tools
Greek Law 4172/2013 created three article-numbered regimes for inbound residents:
Article 5A (Greek non-dom): Annual lump-sum fee of €100,000 covering all foreign-source income, plus €20,000 per qualifying family member. Up to 15 tax years. Eligibility requires investment of €500,000 in Greece (real estate, securities, or business interests) within three years of relocation. The fee replaces ordinary tax on foreign-source income; Greek-source income remains taxed under standard Greek rates.
Article 5B (retirees): 7 percent flat tax on all foreign-source income for retirees who become Greek tax residents and were not Greek residents in 5 of the prior 6 years. Up to 15 tax years. Treaty country residence required.
Article 5C (inbound talent): 50 percent exemption from Greek tax on Greek-source employment and self-employment income for 7 tax years (year of arrival plus 6). Eligibility requires not being a Greek tax resident in 5 of the prior 6 years and a substantial new contract or self-employed activity in Greece.
IFICI: exemption method, not a fee
IFICI under EBF art 58-A taxes qualifying Portuguese-source Cat A and Cat B income at 20 percent flat for 10 years. Foreign-source income from Cat A, B, E, F, and G is exempt under CIRS art 81 n.º 4. Pensions and blacklisted-jurisdiction income are not exempt. The Portuguese mechanism is structurally different: instead of a fee that replaces ordinary tax on foreign income, IFICI reduces Portuguese-source tax on qualifying activity and exempts most foreign-source flows.
When Greece beats Portugal
Three patterns. First, HNW with foreign-source income above the €100,000 fee breakpoint: Greek 5A wins above approximately €1 million annual foreign income for a single resident, depending on the mix and family-member fees. Second, retirees with substantial foreign-pension income: Greek 5B at 7 percent on all foreign income (including pensions) often beats IFICI, because IFICI excludes pensions under CIRS art 81 n.º 4 and pensions in Portugal flow through standard CIRS brackets. Third, inbound talent with high Greek-source comp packages: Article 5C at 50 percent exemption on Greek-source employment runs 7 years, similar in mechanics to Italy's inbound regimes but distinct in scope.
When Portugal beats Greece
Four patterns. First, qualifying Cat A or Cat B activity below the Greek lump-sum breakpoint: IFICI's 20 percent flat plus foreign-source exemption is usually cheaper. Second, HNW families planning multi-generational succession: Portugal's CIS art 6 alínea e) family exemption from Imposto do Selo is structurally cleaner than Greek inheritance rates of 1-10 percent for direct family and up to 40 percent for unrelated heirs. Third, founders sitting on listed-securities holdings: Portugal's post-2024 graduated relief (10/20/30 percent inclusion at 2-5/5-8/8+ years) under CIRS art 72 can deliver an effective rate below Greek capital-gains tax for long-held positions. Fourth, lifestyle plus tax: the Algarve, Lisbon, and Porto draw HNW arrivals where the Greek islands and Athens compete on lifestyle but not always on tax certainty.
Real estate and wealth
Greece levies ENFIA (the Uniform Real Estate Tax) annually on property held by residents and non-residents alike. ENFIA combines a main tax on each property and a supplementary tax for owners with property values above €250,000. Greek property transfer tax runs 3 percent. Portugal levies IMI (CIMI art 112) at 0.3-0.45 percent for urban property and up to 0.8 percent for rural property on VPT (typically 50-70 percent of market value), AIMI for property VPT above €600,000 at 0.7-1.5 percent (CIMI arts 135-A to 135-M), and IMT at acquisition under tiered rates per Lei 73-A/2025. Portugal has no wealth tax outside AIMI's narrow scope. Greece does not levy a personal wealth tax.
Inheritance
Greek inheritance tax runs at progressive rates by class of heir: 1-10 percent for spouse and direct family above the per-heir threshold; 5-20 percent for siblings; up to 40 percent for unrelated heirs. Portugal does not have a stand-alone inheritance tax. Imposto do Selo applies; CIS art 6 alínea e) exempts spouse, descendants, and ascendants. Other beneficiaries pay 10 percent under Verba 1.2 of TGIS, plus 0.8 percent on Portuguese real estate. For multi-generational HNW families, Portugal's family exemption is often the deciding factor.
Corporate tax
Greece applies corporate tax at 22 percent (24 percent in the recent past, lowered in steps). Portugal applies IRC at 17 percent under CIRC art 87 (Lei 64/2025), with SME relief at 15 percent on the first €50,000 (CIRC art 87(2)). For owner-managers structuring around Cyprus, Malta, or BVI holdcos, both PT and GR have CFC and substance regimes that need testing against the actual operating model.
The framework for choosing
PT versus GR depends on income mix and life stage. HNW with €1m+ of foreign-source dividends or rental income tilts to Greek 5A. Retirees with substantial foreign pensions tilt to Greek 5B at 7 percent. Inbound talent with Greek-side employment tilts to Greek 5C (50 percent exemption). Active workers with Cat A or Cat B in qualifying activities tilt to Portuguese IFICI. We model the comparison with your numbers and produce a Position Memo with a recommended sequence.
What this guide is not
This page is general guidance, not advice on your specific situation. Greek-side numerical positions are simplified for comparative reading and would be confirmed by Greek counsel before any decision is acted on.
Frequently Asked Questions
What is the Greek 5A non-dom annual fee?
€100,000 per year for the main resident, plus €20,000 per qualifying family member, under Greek Law 4172/2013 Article 5A. The fee covers all foreign-source income for up to 15 tax years. Eligibility requires a €500,000 Greek investment within three years of relocation.
Is the Greek 7 percent regime the same as Italy's?
No. Greek Article 5B at 7 percent on foreign-source income runs up to 15 tax years and applies broadly to retirees. Italian Article 24-ter TUIR at 7 percent on foreign income runs 9 fiscal years and is restricted to communes of fewer than 20,000 inhabitants in Southern Italy.
How long does Greek 5C inbound-talent relief last?
Up to 7 tax years (year of arrival plus 6) under Greek Law 4172/2013 Article 5C. The relief is a 50 percent exemption on Greek-source employment and self-employment income, conditional on not having been a Greek tax resident in 5 of the prior 6 years.
Does IFICI cover pensions like the Greek 5B regime?
No. CIRS art 81 n.º 4 excludes pensions from the IFICI exemption method. Pensions in Portugal are taxed under standard CIRS brackets after treaty allocation. For retirees with substantial foreign pensions, Greek 5B at 7 percent is often cheaper than Portuguese IFICI.
Which country has lower inheritance tax for direct family?
Portugal. CIS art 6 alínea e) exempts spouse, descendants, and ascendants from Imposto do Selo on gratuitous transfers. Greek inheritance tax for direct family runs 1-10 percent above per-heir thresholds, with up to 40 percent for unrelated heirs.
How is Portuguese real estate taxed compared with Greek ENFIA?
Portugal applies IMT at acquisition (tiered rates), IMI at 0.3-0.45 percent of VPT for urban property annually under CIMI art 112, and AIMI at 0.7-1.5 percent for VPT above €600,000 (CIMI arts 135-A to 135-M). Greece applies ENFIA combining a main tax on each property and a supplementary surcharge for portfolios above €250,000.