Greece: Guidance on exemption from special real estate tax

Regarding procedure and documentation for legal entities owning real estate to be exempt from special real estate tax

Guidance on exemption from special real estate tax

Decision Α.1089/2023 of the Independent Authority for Public Revenues (AADE) amends the currently applicable Decision A.1206/2020 regarding the procedure and required documentation for legal entities owning Greek real estate to be exempt from the special real estate tax (SRET)—an annual 15% tax on the value of Greek real estate. 

One of the most significant amendments relates to the already applicable “disclosure” exemption, under which Greek or EU legal entities (including trusts or other similar vehicles) owning Greek real estate may qualify for exemption from SRET when they disclose the individuals who are their ultimate beneficial owners by having such individuals obtaining a Greek tax registration number.

Decision A.1089/2023 provides that a legal entity seeking exemption from SRET when a foreign trust in involved in its shareholding structure must meet the following requirements:

  • The trust must not be established in a non-cooperative state.
  • The trustee must not be established in a non-cooperative state.
  • The following documents must be submitted:
    • Copy of the trust deed and of any annexes thereto which depict the ultimate (actual) beneficiaries
    • Certificate issued by any public authority or registry of the state where the trust is established, which depicts the ultimate (actual) beneficiaries on the 1 January of the taxable year (or any other document, verification, or print-out from the official website of the authority/registry with similar content). If there is no such authority nor registry, or in case the existing authority does not issue such verifications, a sworn declaration of the trustee can be submitted having the above content or declaring that during the previous 12 months (i.e., since 1 January of the previous year until 1 January of the taxable year) the ultimate (actual) beneficiaries have not been changed (or declare the change, if there has been any) and confirm that issuance of a verification by some public authority is not possible. The ultimate (actual) beneficiaries also must hold a Greek tax registration number. 

Decision Α.1089/2023 also included amendments regarding the procedure for granting certain types of exemptions (e.g., for shipping companies, Greek charitable legal entities, and Greek or EU legal entities held by Greek or foreign charitable institutions), which can now be performed also via the application “My requests” of AADE.

Read a June 2023 report prepared by the KPMG member firm in Greece


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