Greece: Guidelines on tax residency of individuals

Guidelines clarify definition of tax residence, along with criteria for acquiring it

Guidelines clarify definition of tax residence, along with criteria for acquiring it

Circular Ε.2064/2023 introduces guidelines on tax residency of individuals in Greece.

The guidelines clarify the definition of tax residence, along with the criteria for acquiring it, in line with international standards and guidelines, including EU directives and OECD clarifying guidelines on article 4 of the Model Tax Convention (2017 edition).

In particular, the guidelines clarify:

  • Terms “permanent residence,” “habitual abode,” and “center of vital interests”
  • Rules on how to calculate the days of presence of an individual in Greece, as well as how to determine the year during which the individual would be considered for the first-time tax resident of Greece and be obliged to submit an income tax return declaring worldwide income
  • Alternative remedies an individual can seek in case he/she is considered tax resident both in Greece and in some other country (dual tax residence)
  • Obligation of the tax authorities to provide specifically reasoned justification when they decide that an individual is a tax resident of Greece
  • Procedure for changing tax residence for the year following the year of departure and the procedure and documents required during the previous years in accordance with already existing circulars
  • Obligation of the taxpayer to keep the documents evidencing residency in case of a future tax audit

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


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