After the UK closed its non-dom regime in April 2025, two Mediterranean alternatives absorbed most of the displaced capital: Italy’s flat-tax regime for new residents and Greece’s €100,000 alternative tax for HNW individuals. Both shield worldwide foreign income behind a single annual lump sum, both run for fifteen years, and both require you to actually move and spend more than 183 days in the country. The differences only emerge once you look at the price tag, the entry test, and what each country wants in return.
This guide compares them on the points that actually decide the choice for high-net-worth families: the flat-tax bill itself, the investment threshold, family inclusion, the prior-residence test, and what each regime means for entrepreneurs, retirees, crypto holders and remote-work nomads.
Quick Verdict
| Italy | Greece | |
|---|---|---|
| Annual flat tax (foreign income) | €300,000 (raised 2026) | €100,000 |
| Family members add-on | €50,000/yr each | €20,000/yr each |
| Italy-source / Greece-source income | Standard rates (IRPEF, 23–43%) | Standard rates (9–44%) |
| Capital gains (foreign) | Covered by flat tax | Covered by flat tax |
| Capital gains (domestic) | Standard rules | Standard rules |
| Min investment required | None | €500,000+ |
| Prior non-residence required | 9 of last 10 years | 7 of last 8 years |
| Days/year required | 183+ (tax residency) | 183+ (tax residency) |
| Regime duration | Up to 15 years | Up to 15 years |
| Citizenship path | ~10 yrs naturalization | ~7 yrs naturalization |
| Year-1 cost (single applicant) | ≈ €300K + setup | ≈ €600K (€500K invested + €100K tax) |
| Best for | Ultra-HNW, families, brand value | HNW with capital to deploy in Greece |
The headline trade-off: Italy is simpler but more expensive on annual carry (€300K every year, no investment required). Greece is cheaper on annual carry but heavier on entry (one-time €500K investment, then €100K/year). For an investor whose foreign income exceeds roughly €1–1.5M per year, Italy’s flat fee starts paying for itself; below that, Greece’s lower lump sum usually wins on a 5- or 10-year hold.
Tax Treatment Compared
Personal income (foreign-source)
Both regimes operate as substitute taxes (imposta sostitutiva in Italy, alternative tax in Greece). Pay the lump sum and your worldwide foreign income — salaries, dividends, interest, rental, royalties, business profits earned outside the country — drops out of the regular tax base. You do not file detailed schedules for those income streams; the flat tax replaces them entirely.
In Italy, the 2026 Budget Law raised the annual flat tax from €200,000 to €300,000. Anyone admitted before that date is grandfathered at €200K for the remainder of their 15-year window. New entrants from 2026 onward pay €300K. Add-on family members (spouse, children, parents) come in at €50,000 each per year — a meaningful number for multi-generational moves but still cheaper than running each member through the regular system.
In Greece, the alternative tax stays at €100,000 per year for the principal applicant, with €20,000 per included family member. Greece’s regime, introduced in 2019, was always pitched as a “lighter” Italian model and the price gap has widened with Italy’s hike.
Capital gains
Both regimes cover foreign capital gains under the flat tax — selling foreign stocks, foreign real estate, foreign crypto held offshore is included with no separate tax. This is the headline win for both jurisdictions and is a major reason post-Brexit non-doms chose them over UAE or Cyprus (which have their own non-dom mechanics but lack flat-tax simplicity).
Italy carves out one important exception: gains on substantial participations (typically >25% of a private company) sold within the first five years are excluded from the flat tax and taxed at the standard 26% capital-gains rate. Greece has no equivalent carve-out but does require the protected gains to be genuinely foreign-sourced under domestic sourcing rules.
Domestic gains (Italian or Greek securities, Italian or Greek real estate) fall under regular rules. Italy taxes most financial gains at 26%, real estate at sliding scales depending on holding period. Greece taxes most financial gains at 15% and real estate gains at 15% if sold within five years.
Corporate / business income
Neither regime exempts active Italian or Greek business income. If you set up an Italian SRL or a Greek IKE and run a real business, that profit is taxed under standard corporate rules — 24% IRES + ~3.9% IRAP in Italy, 22% corporate tax in Greece (reduced from 24% in recent years).
Both flat-tax regimes are explicitly designed for passive global income holders, not for entrepreneurs running their primary trade locally. If your business is in the US, UK or elsewhere and pays you dividends or fees abroad, both regimes work fine. If you intend to relocate the business itself, you need a separate corporate structure and the flat-tax stops being the dominant lever.
For deeper context on why countries draw this line, see Territorial vs Worldwide Tax and Non-Dom Tax Status.
Residency Requirements Compared
Both regimes require you to become a genuine tax resident — meaning more than 183 days per year in the country, plus the usual indicia (permanent home, family location, center of vital interests). Neither is a “paper residency” where you collect a card and stay abroad; tax authorities in both jurisdictions actively audit physical presence, especially for new flat-tax filers.
The prior-residence test is the gatekeeper:
- Italy requires that you were not an Italian tax resident in 9 of the last 10 tax years. Returning Italians who lived abroad long enough qualify; recent returnees do not. Once admitted, the regime can run for up to 15 consecutive years.
- Greece requires you were not a Greek tax resident in 7 of the last 8 tax years. The window is similar but slightly easier to satisfy. Greece also runs the regime for 15 years and requires you to maintain the qualifying investment throughout.
The investment requirement is the other major split. Italy has none — you simply move, register, and start paying €300K. Greece requires a minimum €500,000 investment in Greek real estate, Greek companies, Greek government bonds or other approved Greek financial instruments. The investment must be made within three years of admission and held for the duration of the regime. This effectively raises Greece’s true entry price.
Both countries integrate with the 183-day rule standardly used across the OECD; tie-breaker rules in their respective tax treaties resolve dual-residency conflicts.
Cost Comparison (Year 1 + Annual)
| Cost item | Italy | Greece |
|---|---|---|
| Flat tax (year 1) | €300,000 | €100,000 |
| Spouse add-on | €50,000 | €20,000 |
| Two children add-on | €100,000 | €40,000 |
| Investment required | €0 | €500,000+ (recoverable asset) |
| Legal / immigration setup | €15,000–€40,000 | €15,000–€35,000 |
| Real estate (rent or buy) | Variable; Milan/Rome from €2,500/mo | Variable; Athens/Glyfada from €1,800/mo |
| Year 1 single applicant total | ≈ €315–340K (cash burn) | ≈ €615–635K (€500K asset + €115K cash) |
| Annual carry from year 2 (single) | €300K | €100K |
| 5-year cumulative (single) | €1.5M | €0.5M (+ retained €500K asset) |
| 10-year cumulative (single) | €3.0M | €1.0M (+ retained €500K asset) |
The 5-year crossover is illuminating. A single applicant on Italy’s regime burns €1.5M in flat tax over five years. A single applicant on Greece’s regime burns €0.5M over five years and still owns a €500K Greek asset (real estate, equities or bonds) at the end. Italy only justifies its premium when the shielded foreign income is large enough that the marginal saving exceeds €200,000 per year — broadly, foreign income of €1.5M+ at the marginal rates the applicant would otherwise pay in their home country.
Lifestyle, Banking & Mobility
Lifestyle. Italy’s expat hubs are Milan (finance, family schooling, Lombardy lifestyle), Rome (institutional, slower pace) and Como/Tuscany (lifestyle-led). Greece’s hubs are Athens (Glyfada and the southern suburbs for affluent expats) and the islands (Mykonos, Paros, Crete) for seasonal residence. Greece is meaningfully cheaper across the board — restaurants, household help, schooling, healthcare. Italy offers more depth: more international schools, more direct flights, more institutional services.
Banking. Both are EU/SEPA jurisdictions with full IBAN access and competitive private banking. Italy has a denser private-banking network (Intesa Sanpaolo Private, Mediobanca, UBS Italy). Greece’s private-banking scene is smaller but functional (Eurobank Private, Alpha Private). For multi-currency or US-asset holders, both jurisdictions support brokerage onboarding without unusual friction.
Mobility. Both passports are top-tier (Italy 187 visa-free, Greece 184 visa-free in current Henley rankings) but neither is required to use the regime — most flat-tax filers retain their home passport for the regime period. Both countries are full Schengen members. Italy has a marginally stronger treaty network (over 100 DTAs) but the gap rarely matters in practice.
Healthcare. Italy’s SSN is one of the better EU public systems; supplemental private cover is widely used. Greece’s ESY is leaner, with private hospitals (Hygeia, Metropolitan) handling most expat care; expect to budget for private health cover from year one.
Which Is Better For…
Entrepreneurs?
Italy wins for the largest income earners. If your foreign business or fund is throwing off €2M+ per year in dividends, fees or carry, Italy’s €300K flat tax is mathematically dominant — and the family add-on at €50K each is competitive for multi-generational planning. Below that income level, Greece’s lower lump sum and lower investment-effective cost are friendlier. See Best Tax-Free Residency for Entrepreneurs for fit by income band.
Digital nomads?
Neither regime is designed for nomads. Both require 183+ days of physical presence and substantial annual commitment. A genuinely mobile remote worker is better served by Cyprus’s 60-day non-dom rule, Portugal’s residency stack, or one of the dedicated digital nomad visa programs. The flat-tax regimes assume you actually want to live in Italy or Greece.
Retirees?
Greece wins on cost. A retiree with foreign pension income, dividends and rental property typically pays well below the €100K/€300K thresholds under the regular system anyway, so the flat tax is rarely the right tool. But for retirees with concentrated investment portfolios (tens of millions in dividend-paying stocks), Greece’s €100K cap is the better cap. Note that Greece also runs a separate 7% pension flat tax for foreign retirees who do not need the full alternative regime — that is often the right product for typical pensioners. Italy has its own separate 7% flat tax for retirees in southern municipalities with under 20,000 inhabitants — a different program entirely from the €300K flat tax.
Crypto founders?
Greece is currently more attractive — narrowly. Foreign-source crypto gains are covered by both flat-tax regimes, but Italy clarified after 2023 that crypto gains realised from Italian residence are taxed at 26% if outside the flat-tax scope, with substantial-participation carve-outs that catch large crypto positions. Greece treats crypto as financial assets at 15% standard but the alternative tax fully covers foreign-realised gains. Either way, both are weaker than Cyprus’s 8% crypto regime or UAE’s 0% personal — see Crypto Founders persona for full ranking.
Frequently Asked Questions
Can I get the Italy flat tax at the old €200K rate?
No — only individuals admitted before the 2026 Budget Law’s effective date are grandfathered at €200K. New applications from 2026 onward fall under the €300K rate. The grandfathered cohort retains their €200K rate for the balance of their 15-year window.
Does Greece’s €500K investment have to be in real estate?
No. Eligible investments include Greek real estate, shares in Greek companies, Greek government bonds, units in Greek mutual funds, and certain other approved Greek financial instruments. Real estate is the most common choice but bonds or fund units are valid and more liquid.
Can a married couple share one Italy flat tax?
No — only the principal applicant pays the €300K flat tax. The spouse is added as a family member at €50,000 per year and is also covered for foreign-income shielding. Children add €50,000 each. The same tier model applies in Greece at €20,000 per family member.
Do I have to give up my home-country residency?
You must transfer your tax residency to Italy or Greece — meaning you cannot remain a tax resident of your prior country under that country’s rules. In practice this means severing center-of-vital-interests ties, often selling or letting your prior home, and ensuring you exceed the 183-day threshold in your new country. See Tax Residency vs Citizenship for the broader framing.
What happens after the 15-year window ends?
Both regimes are non-renewable. After year 15, you fall under the standard tax system of the country in question — Italy’s full IRPEF (top rate ~43% plus regional surcharges) or Greece’s full progressive PIT (top rate 44%). Many flat-tax holders relocate again at year 15, often to a 0% jurisdiction such as the UAE or to a different non-dom regime such as Cyprus or Malta.
Is the regime guaranteed for 15 years?
The legal framework allows up to 15 years, but governments can amend it — Italy already raised the rate from €200K to €300K mid-stream for new entrants. The grandfathering provision protected existing entrants in that round, but a future government could in principle withdraw or restructure. Both regimes have been politically stable so far, but the risk is real and worth modelling.
How long does admission take?
Italy: a binding ruling from Agenzia delle Entrate typically takes 3–6 months from filing; tax residency itself is then triggered by 183-day presence within the calendar year. Greece: admission to the alternative tax regime is typically processed within 60 days, conditional on the investment being completed within three years.
Final Recommendation
If your foreign income is concentrated, very large, and your priority is simplicity plus EU-G7 institutional polish, Italy’s €300K regime is the clean answer — provided the family-of-four math at €450K combined still beats your home-country bill. If you have €500K+ of capital you are happy to deploy in Greek assets, value a meaningfully cheaper annual flat tax, and don’t need Milan’s bandwidth, Greece is the smarter long-run play. Most HNW families we work with end up choosing Greece for the first 5–10 years and revisiting at year 10 — but the right call depends on income shape, family structure, and exit horizon.
Book a free consultation to map your specific income profile against both regimes — and to compare them with UAE, Cyprus and Switzerland’s lump-sum for ultra-HNW alternatives.
Read the full guides:
– Tax-Free Residency in Italy: €300K Flat Tax Regime 2026
– Tax-Free Residency in Greece: €100K Non-Dom Regime
– Non-Dom Tax Status: UK, Cyprus, Malta, Greece Compared
Last updated: 2026-04-26
Sources:
– Agenzia delle Entrate — Regime fiscale per neo-residenti (agenziaentrate.gov.it)
– Italy Legge di Bilancio 2026 (Italian Budget Law)
– Greek Ministry of Finance — Alternative tax regime for foreign-source income (Article 5A, Law 4646/2019)
– PwC Tax Summaries — Italy and Greece individual taxation (taxsummaries.pwc.com)
– Henley & Partners — Italy and Greece residence-by-investment program briefings